U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

For sale by the Superintendent of Documents, U.S. Government Printing Office

Internet: bookstore.gpo.gov Phone: toll free (866) 512–1800; DC area (202) 512–1800

Fax: (202) 512–2250 Mail: Stop SSOP, Washington, DC 20402–0001

89–039 PDF 2004

S. Hrg. 108–245

TERRORISM FINANCING: ORIGINATION,

ORGANIZATION, AND PREVENTION

HEARING

BEFORE THE

COMMITTEE ON 

GOVERNMENTAL AFFAIRS 

UNITED STATES SENATE

ONE HUNDRED EIGHTH CONGRESS

FIRST SESSION

JULY 31, 2003

Printed for the use of the Committee on Governmental Affairs

(

(II)

COMMITTEE ON GOVERNMENTAL AFFAIRS 

SUSAN M. COLLINS, Maine, Chairman 

TED STEVENS, Alaska 

GEORGE V. VOINOVICH, Ohio 

NORM COLEMAN, Minnesota 

ARLEN SPECTER, Pennsylvania 

ROBERT F. BENNETT, Utah 

PETER G. FITZGERALD, Illinois 

JOHN E. SUNUNU, New Hampshire 

RICHARD C. SHELBY, Alabama 

JOSEPH I. LIEBERMAN, Connecticut 

CARL LEVIN, Michigan 

DANIEL K. AKAKA, Hawaii 

RICHARD J. DURBIN, Illinois 

THOMAS R. CARPER, Delaware 

MARK DAYTON, Minnesota 

FRANK LAUTENBERG, New Jersey 

MARK PRYOR, Arkansas 

MICHAEL D. BOPP, Staff Director and Counsel 

DAVID A. KASS, Chief Investigative Counsel 

MARK R. HEILBRUN, General Counsel and National 

Security Advisor to Senator Arlen Specter 

JOYCE A. RECHTSCHAFFEN, Minority Staff Director and Counsel 

DAVID BARTON, Minority Professional Staff Member 

AMY B. NEWHOUSE, Chief Clerk 

(III)

C O N T E N T S 

Opening statements: Page 

Senator Collins ................................................................................................. 1

Senator Specter ................................................................................................. 3

Senator Akaka .................................................................................................. 13

Senator Lautenberg .......................................................................................... 16

Senator Coleman .............................................................................................. 17

Senator Levin .................................................................................................... 18

Senator Pryor .................................................................................................... 22

Senator Carper ................................................................................................. 24

WITNESSES 

THURSDAY, JULY 31, 2003

John S. Pistole, Acting Assistant Director for Counterterrorism, Federal Bureau of Investigation ............................................................................................ 4

R. Richard Newcomb, Director, Office of Foreign Assets Control, U.S. Department of the Treasury ........................................................................................... 7

Dore Gold, Former Israeli Ambassador to the United Nations, and President, 

Jerusalem Center for Public Affairs ................................................................... 25

Jonathan M. Winer, Alston and Bird ..................................................................... 28

Steven Emerson, Executive Director, The Investigative Project ......................... 31

ALPHABETICAL LIST OF WITNESSES

Emerson, Steven: 

Testimony .......................................................................................................... 31

Prepared statement .......................................................................................... 131

Gold, Dore: 

Testimony .......................................................................................................... 25

Prepared statement with attachments ........................................................... 77

Newcomb, R. Richard: 

Testimony .......................................................................................................... 7

Prepared statement with attachments ........................................................... 54

Pistole, John S.: 

Testimony .......................................................................................................... 4

Prepared statement .......................................................................................... 45

Winer, Jonathan M.: 

Testimony .......................................................................................................... 28

Prepared statement .......................................................................................... 110

APPENDIX

Council on American-Islamic Relations (CAIR), Nihad Awad, Executive Director, prepared statement with an attachment .................................................... 176

Questions and Responses for the Record from: 

Mr. Pistole ......................................................................................................... 180

Mr. Newcomb .................................................................................................... 185

Mr. Gold ............................................................................................................ 190

Mr. Winer .......................................................................................................... 192

Mr. Emerson ..................................................................................................... 194

(1)

TERRORISM FINANCING: ORIGINATION, 

ORGANIZATION, AND PREVENTION 

THURSDAY, JULY 31, 2003

U.S. SENATE, COMMITTEE ON GOVERNMENTAL AFFAIRS, Washington, DC. 

The Committee met, pursuant to notice, at 10:16 a.m., in room 

SD–342, Dirksen Senate Office Building, Hon. Susan M. Collins, 

Chairman of the Committee, presiding. 

Present: Senators Collins, Coleman, Specter, Levin, Akaka, Carper, Lautenberg, and Pryor. 

OPENING STATEMENT OF CHAIRMAN COLLINS 

Chairman COLLINS. The Committee will come to order. 

Today, the Committee on Governmental Affairs is holding a 

hearing on the financing of terrorism. Terrorism costs money. From 

funds needed to buy explosives and airline tickets, to living expenses, to payoffs to the families of suicide bombers, terrorists 

must have constant and untraceable sources of money. Stopping 

the flow of these funds is a formidable task. Osama bin Laden is 

an experienced financier who once reportedly boasted that he and 

other al-Qaeda leaders know the cracks in the Western financial 

system like the lines on their own hands. 

Immediately after the September 11 attacks, the President took 

strong action to close the gaps in our financial system by issuing 

Executive Order 13224 to block terrorist funds. Nevertheless, serious questions persist about whether we are doing enough. There 

are even more serious questions about whether some of our allies 

are doing enough. 

Last year, the Council on Foreign Relations issued a report contending that U.S. efforts to curtail terrorism financing are impeded, 

‘‘not only by a lack of institutional capacity abroad but by a lack 

of political will among American allies.’’

The report concludes that our government appears to have responded to this lack of will with a policy decision not to use the 

full power of our influence and legal authority to compel greater cooperation. 

A key nation in the fight against terrorist financing is Saudi Arabia. It appears that from the joint inquiry by the House and Senate 

Intelligence Committees, which examined the kingdom’s role in terrorist financing, that it is difficult to tell for sure exactly what the 

extent of the Saudi involvement is because almost an entire chapter regarding foreign support for the September 11 hijackers is 

classified. Even the parts that were published, however, raise seriVerDate 0ct 09 2002 08:39 Jan 30, 2004 Jkt 089039 PO 00000 Frm 00005 Fmt 6633 Sfmt 6633 C:\DOCS\89039.TXT SAFFAIRS PsN: PHOGAN
2

ous concerns about Saudi Arabia’s role in the September 11 attacks. 

For example, the unclassified portion of the joint inquiry report 

describes the activities of Omar al-Bayoumi, a man who apparently 

provided extensive assistance to two of the September 11 hijackers. 

According to the report, a source told the FBI that he thought alBayoumi must have been a foreign intelligence officer for Saudi 

Arabia or another power. The report also finds that al-Bayoumi 

had access to ‘‘seemingly unlimited funding from Saudi Arabia.’’ AlBayoumi is now reported to be living in Saudi Arabia. 

Last month, the General Counsel of the Treasury Department 

testified before the Terrorism Subcommittee of the Judiciary Committee that in many cases Saudi Arabia is the ‘‘epicenter’’ of terrorist financing. The Council on Foreign Relations report found 

that for years individuals and charities based in Saudi Arabia have 

been the most important source of funds for al-Qaeda and that for 

years Saudi officials have turned a blind eye to this problem. 

As our witnesses Ambassador Dore Gold and Steven Emerson 

will describe in some detail, there is evidence that enormous sums 

of money flow from Saudi individuals and charitable organizations 

to al-Qaeda, to Hamas, and other terrorist organizations. The key 

question now is whether the Saudi Government is doing enough to 

stop the flow of this money, and if not, what actions the U.S. Government should take to prompt the Saudis to take more effective 

action. The Saudi Government recently announced some changes in 

its banking system and charity laws, but it is not clear that these 

changes go far enough or will be truly effective. 

We are fortunate to have with us today key counterterrorism officials from the FBI and the Department of Treasury. They will describe the administration’s actions against terrorism financing, and 

they will help us better understand the level of cooperation our 

country is receiving from the Saudi and other governments. We 

also have three experts to discuss their views regarding the fight 

against terrorist financing generally and Saudi Arabia’s role specifically. 

As the discussion of the joint inquiry report has made clear, 

there are still many questions about Saudi Arabia’s role, even if 

that role is inadvertent, in the September 11 attacks and about the 

extent of the Saudi Government’s cooperation in the fight against 

terrorism. I hope today’s hearing will help us get answers to some 

of these questions and will highlight areas in which our government needs to refocus its efforts in order to stop the flow of funds 

to terrorists. 

I am very pleased today to pass the gavel to Senator Specter, 

who spearheaded this investigation and is one of the Senate’s leaders in the war against terrorism. He has served as the Chairman 

of the Senate Intelligence Committee. He chaired a hearing about 

this very subject last November in the Judiciary Committee, and 

he has continued to investigate this matter as a Member not only 

of this Committee but the Judiciary Committee as well. 

This hearing today is particularly timely given the release last 

week of the joint inquiry report on the September 11 attacks. I applaud Senator Specter for his leadership in this area, and I am 

pleased to join him in working on an issue and a challenge to our 

3

country that has profound impact on the safety of our Nation and 

all law-abiding nations. 

Senator Specter. 

OPENING STATEMENT OF SENATOR SPECTER 

Senator SPECTER [presiding.] Thank you very much, Madam 

Chairman, Senator Collins. At the outset I compliment you on the 

outstanding job you are doing in chairing this very important Committee, a brief meteoric career so far in the U.S. Senate, and I 

thank you for your leadership on this important subject and for cooperating in this investigation and in this hearing and for handing 

me this mighty gavel. I appreciate it very much. 

The issue of the financing of terrorists is one of enormous importance, and the Saudi role is especially important in the wake of the 

very extensive report published on September 11 with 26 missing 

pages identified as being Saudi involvement. There has been a decision by the Executive Branch not to release those pages, and I believe that puts a greater responsibility on Congress in oversight on 

hearings just like this. 

The question of Saudi cooperation with the United States has 

been on my agenda for the better part of the last decade. When I 

chaired the Senate Intelligence Committee in the 104th Congress, 

I went to Khobar Towers, investigated the matter, and talked to 

the Crown Prince as part of a U.S. effort to get cooperation from 

the Saudis. And while they profess to be very cooperative, the fact 

was that they were very uncooperative. There had been a car 

bombing in Riyadh in 1995 where Americans were killed. Federal 

officials were not permitted to talk to the suspects. They were beheaded by the Saudi Government so that we never did find out 

what they had to say. And then on June 25, 1996, Khobar Towers 

was blown up, 19 airmen killed, 400 airmen wounded, and the 

issue has never yet been fully resolved. 

A criminal indictment was returned naming Iran as a co-conspirator, and questions linger to this day as to whether some of 

those who were involved in Khobar Towers might have been involved in September 11. And our hearing today is going to probe 

this issue further to see if we can shed some light as to what the 

Saudi involvement is. 

The business of the financing of terrorism has broader scope, 

which we have investigated on the Judiciary Committee, last year 

a hearing on the financing of Hizbollah. They go into a small town 

in North Carolina and reap millions of dollars on cigarette smuggling, which goes to show you the scope of the tentacles. Hamas is 

raising money in the United States, and we are pursuing an investigation to identify those who contribute to Hamas with a thought 

to hold them liable as accessories before the fact to murder. 

When you contribute to a known terrorist organization and that 

terrorist organization then murders American citizens, those people 

who contribute knowingly could be indicted and prosecuted for 

being accessories before the fact to murder. And Saudi Arabia contributes reportedly about $4 billion a year to so-called charities 

which have dual purposes. And we really need to pull back the covers on this item, and this is a real challenge for the U.S. Government, and congressional oversight is a very important part. 

4

1The prepared statement of Mr. Pistole appears in the Appendix on page 45. 

We have some expert witnesses today from the Federal Bureau 

of Investigation and from the Treasury Department who will detail 

efforts to identify Saudi contributions, and we have experts who 

have been in government, former Ambassador to the UN, Dore 

Gold, and others on a second panel. 

We are going to establish the time of 5 minutes for opening 

statements. Everything prepared in writing will be, as usual, made 

a part of the record, but that will leave us the maximum time for 

questions and answers. 

Our first witness is John Pistole, Deputy Executive Assistant Director for Counterterrorism of the Federal Bureau of Investigation. 

Welcome, Mr. Pistole, and the floor is yours. 

TESTIMONY OF JOHN S. PISTOLE,1 ACTING ASSISTANT DIRECTOR FOR COUNTERTERRORISM, FEDERAL BUREAU OF INVESTIGATION 

Mr. PISTOLE. Thank you, Senator Specter and Madam Chairman 

Collins. Thank you for the opportunity to be here today, and I will 

just take a couple of minutes, if I may, to make two points and 

then, as you mentioned, Senator Specter, to allow maximum time 

for questions. 

The first point is the FBI’s focus on terrorism financing and the 

radically changed organization that the FBI is today compared to 

prior to September 11, where today we have as our overriding emphasis the prevention of terrorist activity in the United States or 

against U.S. interests overseas. A key component of that is the 

identification of individuals involved in the financing of potential 

terrorist activity and trying to identify the full scope of the enterprise, the individuals associated with this group that is raising 

money that may be going to terrorist financing. And we see that 

as one of the key means of being able to disrupt and dismantle terrorist cells that may be operating here in the United States or 

overseas that may be targeting U.S. interests. 

The second point that I would like to make is talking about the 

unprecedented cooperation that we have had with not only our law 

enforcement and intelligence community partners here in the 

United States since September 11 but also with foreign partners in 

both the law enforcement and intelligence communities in addressing terrorism matters overall. Terrorism financing remains one of 

those challenging issues that certain countries such as Saudi Arabia we believe can do more in, and we will address that shortly. 

In terms of the FBI’s response to September 11, I think the Committee is quite aware of the FBI’s response in creating the Terrorist Financing Operations Section, or TFOS for short, which 

originally looked at the 19 hijackers and detailed every financial 

transaction that they conducted, overseas money coming in to them 

or while they were here in the United States. TFOS has evolved 

from that time into the central entity responsible for coordinating 

all terrorist financing investigations for the FBI and then working 

in concert with, again, our domestic law enforcement and intelligence community partners. And with me today is Dennis Lormel, 

the chief of the Terrorist Financing Operations Section, who has 

5

been almost singularly responsible to develop and implement the 

TFOS strategy. 

What TFOS has been doing is trying to follow the money, to 

identify those individuals who may be involved in terrorist financing and then to trace that money with law enforcement and intelligence aspects to ascertain where that money is going. And one of 

the key aspects of what the FBI is doing post-September 11 is addressing every terrorist investigation as an intelligence-driven investigation as opposed to strictly a law enforcement investigation. 

The key here is to use all the tools available to us, whether it 

is the FISA court and the intercepts we are able to obtain through 

the FISA court, national security letters, any of the other tools 

available to us as a member of the intelligence community, and 

then to focus that investigation on the intelligence aspect, coupled 

with the law enforcement sanctions and tools that we have if we 

need to bring charges against individuals to take them off the 

street if they pose a threat or to elicit their cooperation. 

Given that background and that new paradigm that the FBI has 

employed since September 11, TFOS has followed the terrorist trail 

in a number of situations, and rather than go into the detail that 

is enumerated in my statement, I will just touch briefly on a couple 

of the successes in general terms. 

One of the key areas has been our outreach with and cooperation 

from the private sector. In that area, for example, we have developed the ability to conduct real-time monitoring of specifically identified financial activity, which has been invaluable not only to investigations here in the United States but to some of our foreign 

partners who have relied on that information, tracking money 

going from the U.S. overseas that may be used in terrorist activity 

and vice versa. 

In support of a specific high-profile joint terrorist investigation 

on financing, a number of countries and agencies, such as United 

Kingdom, Switzerland, Canada, and Europol, have detailed their 

investigators to TFOS on a temporary-duty basis. We have engaged 

in extensive coordination with authorities of numerous foreign governments in terrorist financing matters, which has led to joint investigative efforts around the world, including identifying and exploiting the financing of several overseas al-Qaeda cells, including 

those in Indonesia, Malaysia, Singapore, Spain, and Italy. 

There are a number of other relationships that have been established with central banks of foreign countries that have also enabled us to track terrorist funding in a way that we simply did not 

do prior to September 11. 

The other aspect that is critical here is the information sharing 

where our greatest successes have come in the interagency forum, 

where we are part of the National Security Council’s Policy Coordinating Committee on terrorist financing, which was created in 

March 2002. The information sharing we have found has simply 

been critical to any success we have had, and especially our relationship with the Central Intelligence Agency in some sensitive ongoing matters has allowed us to develop an expertise that simply 

the U.S. Government did not have prior to September 11. 

Senator Specter, you mentioned the case in Charlotte, North 

Carolina, as one example. There are numbers of other examples 

6

which, again, I won’t go into at this time. They are in my statement. 

The other point that I want to touch on is the cooperation of the 

foreign governments, and specifically Saudi Arabia. As we all 

know, late on the evening of May 12 of this year, three large bombs 

were detonated in Western housing complexes of Riyadh, Saudi 

Arabia. The next day, I was on a flight to Riyadh to lead an assessment team of the FBI, working with the CIA, to assess what the 

Saudi Government, specifically the Mabahith, the Saudi counterpart of the FBI, would allow us to do in terms of bringing a team 

of investigators and experts in to go through the crime scenes, to 

talk to witnesses, and to assess who may be responsible for those 

acts. 

As a result of the discussions, the Saudis allowed us to bring 75 

FBI employees and an undisclosed number of agency people in to 

not only go through the crime scene, comb through it with shovels 

and screens, but also to analyze DNA from some of the human remains that were there, to do forensic tests on any and all evidence. 

They also gave us access to Saudi citizens who were witnesses to 

those three heinous acts. 

To summarize, what they did after May 12, which I believe was 

a defining moment for the Saudis because al-Qaeda attacked Saudi 

interests in their homeland, what they allowed us to do was unprecedented. You mentioned the Khobar Towers and the OPM–

SANG bombing prior to that where, frankly, we were frustrated beyond any recognition to accomplish what we were hoping to do, as 

you are well aware, Senator Specter. 

What I would say is that post-May 12, the Saudis have had a 

wake-up call, and we have had unprecedented cooperation with 

them in virtually every area. To that end, the one key area and the 

focus of today’s hearing is on terrorist financing. The Saudis last 

year made a number of representations and enacted a number of 

laws designed to identify and dismantle terrorist financing that 

may be emanating from Saudi. From our position, the jury is still 

out on the effectiveness of what they have done. We simply have 

not seen the results of those initiatives from a terrorism financing 

perspective. Since May 12, they have arrested hundreds of people, 

either detained or killed in an attempt to apprehend——

Senator SPECTER. Where do you say the jury is out? On what 

issue? 

Mr. PISTOLE. On the terrorism financing issue as far as the effectiveness of the Saudi initiatives to stem the tide of financing 

through NGOs or charitable organizations. 

Senator SPECTER. When the question and answer period comes, 

we are going to ask you when you think the jury will be in on that. 

Mr. PISTOLE. OK. 

Senator SPECTER. We would like to know. Could you sum up at 

this point? 

Mr. PISTOLE. Yes. I would be glad to, Senator. 

As a follow-up to a number of ongoing measures, there is a National Security Council team that is leaving Sunday to go to Riyadh, which I am participating in with State Department and 

Treasury Department senior officials, who are meeting with senior 

7

1The prepared statement of Mr. Newcomb with attachments appears in the Appendix on page 

54. 

Saudi officials to address a number of the issues that may arise in 

this hearing today. 

That would conclude my opening statement. 

Senator SPECTER. OK. Thank you very much, Mr. Pistole. 

Our next witness is Rick Newcomb, who is the Treasury Office 

of Foreign Assets Control Director. Thank you for joining us, and 

we look forward to your testimony. 

TESTIMONY OF R. RICHARD NEWCOMB,1 DIRECTOR, OFFICE 

OF FOREIGN ASSETS CONTROL, U.S. DEPARTMENT OF THE 

TREASURY 

Mr. NEWCOMB. Thank you, Senator Specter, Madam Chairman, 

Members of the Committee. I am pleased to have the opportunity 

to testify this morning about our efforts to combat terrorist support 

networks that threaten U.S. citizens and property worldwide. 

The threat of terrorist support networks and financing is real. It 

has been our mission to help identify and disrupt these networks. 

There is much we know about how radical Islamic terrorist networks are established and still thrive. Wealthy individuals and influential individuals and families based in the Middle East have 

provided seed money and support to build a transnational support 

infrastructure that terrorists have used for their purposes. This 

network, fueled by deep-pocket donors and often controlled by terrorist organizations, their supporters, and those willing to look the 

other way, includes or implicates banks, businesses, NGOs, charities, social service organizations, schools, mosques, madrassas, and 

affiliated terrorist training camps and safe houses throughout the 

world. 

The terrorist networks are well entrenched, self-sustaining, 

though vulnerable to the United States, allied, and international 

efforts applying all tools at our disposal. Today, I will explain our 

efforts being implemented in coordination with other Federal agencies, including the Departments of Defense, State, Justice, Homeland Security, the FBI, the intelligence community, and other agencies to choke off the key nodes in the transnational terrorist support infrastructure. 

The primary mission of the Office of Foreign Assets Control of 

the Treasury Department is to administer and enforce economic 

sanctions against targeted foreign countries and foreign groups and 

individuals, such as terrorists, terrorist organizations, and narcotics traffickers, which pose a threat to the national security, foreign policy, or economy of the United States. We act under the general Presidential wartime and national emergency powers, as well 

as specific legislation, to prohibit transactions and block or freeze 

assets subject to U.S. jurisdiction. The origin of our involvement in 

the fight against terrorism stems from the initial conception of terrorism as being solely state-sponsored. Our mandate in the realm 

of terrorism was to compile available evidence establishing that 

certain foreign entities or individuals that were owned or controlled 

by, or acting for or on behalf of, a foreign government subject to 

an economic sanctions program. Such entities and individuals beVerDate 0ct 09 2002 08:39 Jan 30, 2004 Jkt 089039 PO 00000 Frm 00011 Fmt 6633 Sfmt 6633 C:\DOCS\89039.TXT SAFFAIRS PsN: PHOGAN
8

came known as SDNs and are subject to the same sanctions as the 

foreign government to which they are related. 

The President harnessed these powers and authorities in launching the economic war against terrorism in response to the terrorist 

attack of September 11 and pursuant to the powers available to the 

President under the International Emergency Economic Powers 

Act. President Bush issued Executive Order 13224, entitled ‘‘Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten to Commit, or Support Terrorism,’’ declaring that 

acts of grave terrorism and threats of terrorism committed by foreign terrorists pose an unusual and extraordinary threat to the national security, foreign policy, or economy of the United States. 

This order prohibits U.S. persons from transacting or dealing with 

individuals or entities owned or controlled, acting for or on behalf 

of, assisting or supporting, or otherwise associated with persons 

listed in the Executive Order and those designated under the Executive Order as specially designated global terrorists. 

After the September 11 attacks, President Bush rallied the international community to unite in the economic war on terrorism. The 

U.S. Government has worked with the United Nations to pass resolutions that parallel U.S. authorities to designate entities supporting al-Qaeda. The international community, including our allies in the Persian Gulf, joined us and have committed to fully cooperating on all fronts against al-Qaeda and its supporters. On a 

regular basis, for example, the United States works cooperatively 

with Saudi authorities on issues relating to the war on terrorism. 

In some areas, cooperation is routine and systematic. In others, especially those touching aspects of terrorist financing and infrastructure, which touches all aspects of government, coordination is more 

complex. 

We have acted with Saudi Arabia and other allies in targeting 

al-Qaeda and other terrorist infrastructure. These actions have included a number of multilateral efforts that many times resulted 

in notifying and listing at the United Nations under United Nations Security Council Resolutions 1267 and 1455. 

Some of the terrorist supporters we targeted include financial 

networks, including the al-Barakaat network, a Somalia-based 

hawala operator that was active worldwide. And the Muslim Brotherhood-backed Nasreddin financial services network. Other efforts 

have targeted charitable fronts based in the United States, including the Benevolence International Foundation, Global Relief Foundation, and the Holy Land Foundation, and foreign-based charitable fronts including branch offices of the Revival of Islamic Heritage Society and the Afghan Support Committee. We also acted with 

our allies against major al-Qaeda-affiliated organizations such as 

Jemaa Islamiyah. 

In the coming months, we are seeking to significantly expand 

these efforts and impact the implementation of the President’s authorities under the Executive Order by adopting a more systematic 

approach to evaluating the activities of major terrorist organizations in various regions. This approach will focus on identifying key 

nodes that sustain the abilities of terrorist organizations to remain 

operational despite successful actions by the United States and its 

9

allies to capture and arrest terrorists, cell members, leaders, and 

operational planners. 

In furtherance of this end, we have initiated a collaborative effort 

with the Department of Defense and other agencies to develop information and strategies against terrorist financing and infrastructure. Last fall, we began a pilot project with the U.S. Pacific Command and other DOD elements that identified terrorist support 

networks in Southeast Asia and selected key nodes or priority targets in these networks. The project focused special attention on alQaeda network affiliates in PACOM’s AOR, including Jemaa 

Islamiyah, which subsequently carried out the Bali bombings, and 

the Abu Sayaff Group and others. This approach identified the key 

leaders, fundraisers, businessmen, recruiters, companies, charities, 

mosques, and schools that were part of its support network. Thus 

far, we have imposed sanctions against two of these key nodes and 

are coordinating actions against several others. 

This process is the model that we are seeking to continue and expand in the collaborative efforts with DOD agencies and the combatant commands. We are working with USEUCOM headquarters. 

Meetings in the near future are planned to lay the groundwork for 

a continuing joint project. We also plan to begin projects with the 

Central Command Southern Command shortly thereafter. Working 

with these commands and other agencies provides us and DOD 

partners with, in effect, a force multiplier that brings together a 

variety of counterterrorism tools and resources to enhance opportunities for future efforts. 

Taking a regional approach, following the various command’s 

areas of responsibility, this effort will seek to identify and isolate 

the key nodes of the transnational terrorist support infrastructure 

in the respective AORs. This approach seeks to provide the opportunity to cripple an entire organization at one time through our implementation of the President’s authority in coordination with possible actions in other departments and agencies and in cooperation 

with our allies at the UN. 

We have already taken steps to implement this approach in some 

regions. For example, we are working with other DOD agencies, including the Office of Naval Intelligence, to fully identify the terrorism support infrastructure in the Horn of Africa. In this region, 

shipping and related drug-smuggling activities appear to be 

strengthening the terrorist networks in this area. Working with 

ONI provides us the opportunity to work with analysts who have 

unique experience in other areas less accessible to us. 

I have today a few graphical representations of the key nodes approach that could be applicable to a terrorist support network in 

any region. It is related in Appendix 2 of my written testimony. 

Charts 1 and 2 are examples of the various steps of the funding 

process. Donors provide money to a variety of intermediaries often 

acting on behalf of charitable organizations to collect funds. The 

charitable organizations in turn use the funds both for legitimate 

humanitarian efforts but also, either wittingly or unwittingly, allow 

some funds to be siphoned off by facilitators who serve as the conduit to the extremist groups. Facilitators frequently are employees 

of the charitable organizations with close ties to the extremist 

10

groups or members of the extremist group with responsibility for 

liaising with charitable organizations. 

Chart 2 is a theoretical model of how the key nodes of the terrorist support structure can be more systematically identified in 

their respective levels of participation in the funding network. 

Chart 3 is a model of a terrorist support network with the key 

nodes highlighted that we believe economic sanctions could effectively impact. These include financial, leadership, and influence 

nodes, which are color-coded in red, blue, and green. Influence 

nodes can include individuals and institutions that provide spiritual or other guidance or serve as recruitment centers. 

Chart 4 shows theoretically how designation and——

Senator SPECTER. Before you leave Chart 3, what does Chart 3 

show? 

Mr. NEWCOMB. Chart 3 shows in green the financial targets, in 

red the leadership targets, in purple the influence targets. And by 

using an effects-based targeting approach, we are able on an interagency basis to identify who the key leaders of these various participating entities are so that when taking them out, we can result 

in Chart 4, which shows theoretically how designation will isolate 

the key nodes of Chart 3 and sever the critical ties within the overall network and thereby disrupt its overall functioning. By removing these key nodes of the support structure, the leadership, the influence, the financial, the terrorist group is unable to mobilize people and resources in support of terrorists, thus rendering it ineffective. 

The funds necessary for a terrorist organization to carry——

Senator SPECTER. Mr. Newcomb, you are double time now plus. 

Would you sum up? And we will go to Q and A. 

Mr. NEWCOMB. I have perhaps another minute. 

Senator SPECTER. OK. 

Mr. NEWCOMB. The funds necessary for a terrorist organization 

to carry out an attack often are minimal, but the support infrastructure critical for indoctrination, recruitment, training, logistical 

support, the dissemination of propaganda, and other material requires substantial funding. The President’s power under Executive 

Order 13224, as well as other legislation, provide the United States 

with authorities that are critical to attacking this threat posed by 

these terrorist organizations. Our effectiveness in implementing 

these authorities requires strong coordination with other U.S. departments and agencies and support from U.S. allies under United 

Nations Security Council Resolutions 1267 and 1455. 

Terrorist organizations including al-Qaeda, the Egyptian Islamic 

Jihad, Jemaa Islamiyah, Al-Ittihad Al-Islamiyya, Hamas, Hizbollah, and others rely on their infrastructure for support and to 

shield their activities from scrutiny. The secretive nature of their 

activities and their frequent reliance on charitable, humanitarian, 

educational, and religious cover are vulnerabilities we can exploit 

by making designations under the Executive Order. Decisive action 

against high-impact targets deters others, forcing key nodes of financial support to choose between public exposure of support for 

terrorist activities or tarnishing their reputation, to the detriment 

of their business and commercial interest. 

Thank you, Senator. 

11

Senator SPECTER. We will now proceed with questioning, 5-

minute rounds, and the Chairman has deferred to me for the first 

round. 

Mr. Newcomb, in interviews by staff preparatory to your coming 

here, you advised that a good many of your recommendations for 

sanctions were rejected. Would you amplify what has happened on 

that? 

Mr. NEWCOMB. Yes, Senator. In identifying key nodes, our responsibility is to identify how these terrorist organizations fit their 

activities together. 

Senator SPECTER. Well, after you have identified them and made 

the recommendation—I only have 5 minutes. I want to focus very 

sharply on the rejections on the recommendations which involve 

Saudi sources. Precisely what has happened on that? 

Mr. NEWCOMB. Well, the designation, as we indicated in our discussions, is not the only possible action. There is also law enforcement, intelligence, diplomatic, and military——

Senator SPECTER. Well, let’s focus on economic sanctions, which 

is my question, before we go into other possible actions. I want to 

know about the recommendations on economic sanctions as to 

Saudis which have been turned down. 

Mr. NEWCOMB. Senator Specter, we have made numerous recommendations, including relating to Saudi Arabia and other terrorist support organizations and groups. This goes through a Policy 

Coordinating, PCC process, where all the equities of the government come to the table, including——

Senator SPECTER. Well, my question focuses on recommendations 

which you have made for sanctions as to Saudi organizations which 

have been rejected. 

Mr. NEWCOMB. Well, first let me say it is not—it is the policy not 

to comment on internal policy deliberations within the government. 

I can tell you these issues have been discussed with all the key 

players at the table, and when there is another possible action that 

can be taken, we have achieved our goal by teeing issues up. 

Senator SPECTER. I am not asking about internal deliberations. 

I am asking you—and let me be specific with some organizations 

which have been discussed with you by staff prior to your coming 

here. 

Were there recommendations as to the National Commercial 

Bank of Saudi Arabia for economic sanctions which were rejected? 

Mr. NEWCOMB. No, Senator Specter, there was not. 

Senator SPECTER. Were there recommendations for sanctions 

against the World Assembly of Muslim Youth? 

Mr. NEWCOMB. There, as in others, these are issues that we 

looked at and examined very carefully. There was no recommendation out of our office on either of those. 

Senator SPECTER. Well, what conclusions did you come to on the 

World Assembly of Muslim Youth? 

Mr. NEWCOMB. That along with the whole variety of charitable 

organizations operating head offices in Saudi are organizations 

that we are looking at, as well as the whole range of several hundred or so possible organizations that may be funding terrorist activities. Rising to the level of a recommendation is a complicated 

policy——

12

Senator SPECTER. Well, I am not concerned about several hundred others. I would like to know, what about the World Assembly 

of Muslim Youth? Were they funding terrorist organizations, subject to economic sanctions, without any action being taken? 

Mr. NEWCOMB. I can not conclude that in this hearing today. It 

is an organization that we——

Senator SPECTER. You can or you can not conclude——

Mr. NEWCOMB. Cannot. 

Senator SPECTER. At this hearing today? 

Mr. NEWCOMB. Well, we did not conclude that in our deliberations, so I can not say that was a recommendation of our office. 

Senator SPECTER. How about the International Islamic Relief Organization? Were there recommendations for sanctions there which 

were rejected by higher officials in the Treasury Department? 

Mr. NEWCOMB. This is an issue that we looked at, and, again, 

your question relates to policy deliberations within the administration which I can not comment on. I can tell you we did look at that 

organization. 

Senator SPECTER. I am not interested in your policy deliberations. What I am interested in is your conclusions. Were there economic sanctions taken against the International Islamic Relief Organization? 

Mr. NEWCOMB. To date, there have not been as of this date. 

Senator SPECTER. Do you think there should be? 

Mr. NEWCOMB. It is something that we would look at very carefully along with the others participating in the policy process. 

Senator SPECTER. Well, when you look at it very carefully, how 

long have you been looking at it up until now? 

Mr. NEWCOMB. Certainly since immediately in the aftermath of 

September 11. 

Senator SPECTER. Well, that is almost 2 years. How long will it 

take you to come to a conclusion? 

Mr. NEWCOMB. We can recommend and we can designate, but 

there is a policy process which takes into account all the variety 

of——

Senator SPECTER. I have got 16 seconds left. Have you recommended as to any of the organizations I have mentioned to you 

some tough economic sanctions which were turned down by higher 

officials, implicitly because they were Saudi organizations? 

Mr. NEWCOMB. I can not say it is because they were Saudi organizations. 

Senator SPECTER. Well, could you say whether they were turned 

down? 

Mr. NEWCOMB. I can say that there have been some charities and 

other organizations that we have considered, we have had at the 

table, and that have been deferred for other actions which I would 

deem as appropriate. 

Senator SPECTER. Well, my red light went on in the middle of 

your last answer, but I will be back. 

Mr. NEWCOMB. OK. 

Senator SPECTER. Senator Akaka. 

13

OPENING STATEMENT OF SENATOR AKAKA 

Senator AKAKA. Thank you very much, Mr. Chairman, for holding this hearing on terrorism financing. 

I agree with my colleagues Senator Shelby and Senator Graham, 

who say that we need to make public much of the information from 

a congressional report on intelligence and the activities surrounding the terrorist attacks of September 11, 2001. There needs 

to be a full and open debate on these issues. And this is an effort 

partly today at this hearing. 

I am also concerned about terrorism in Africa, and I think that 

we should put an end to the illicit trade in so-called blood diamond 

funds, which funds activities of Liberian President Charles Taylor, 

and also supports conflicts in Angola and the Congo. 

I am equally concerned about terrorism in Asia. We must stop 

the activities of terrorists in Bali and the laundered money there 

that financed the bombing in Bali. These confront us as we look 

into Saudi Arabia and our tracking and coordinating intelligence 

with them and the lack of some of this information from them. 

What we are learning is that there is a lesson that we cannot 

afford to ignore, and this Committee is certainly moving out on 

this. 

Mr. Pistole, the House-Senate September 11 Commission report 

states that intelligence resources to fight terrorism are stretched 

thin. Do you believe that the FBI has adequate resources, people, 

and funding for training in place to combat terrorism? 

Mr. PISTOLE. Senator, you have identified some critical issues for 

the FBI in terms of ensuring adequate training. To answer your 

question, I believe we have sufficient personnel, nearly 29,000 employees right now, over 11,000 of whom are special agents, to address the counterterrorism issue facing the United States domestically. But it is through the enhancement or augmentation through 

the Joint Terrorism Task Forces where we have over 2,000 FBI and 

other agency, law enforcement, and intelligence community personnel dedicated to 84 JTTFs around the country that we’re able 

to leverage our limited resources in an effective means of being the 

arms and the operational node of the U.S. Government in fighting 

terrorism in the United States 

Senator AKAKA. Mr. Pistole and Mr. Newcomb, we know there 

are frustrations, as you mentioned, Mr. Pistole, about what we are 

doing about tracking and coordination. My question to each of you 

is: What more needs to be done to improve tracking and coordination of terrorist funding intelligence? 

Mr. PISTOLE. I think one of the keys is to achieve the cooperation 

of foreign governments such as Saudi Arabia where the assessment 

is much of the funding stems from, and as I mentioned earlier, I 

am leaving Sunday to go to Jiddah. I hope to achieve some success 

in that arena with my colleagues from Treasury and from State 

and from the National Security Council. 

There are a number of issues on the table that will be discussed, 

and I would be willing to give the Committee a follow-up briefing 

after that trip, if they so desired. 

Senator AKAKA. Mr. Newcomb. 

Mr. NEWCOMB. Thank you, Senator. I share my colleague’s point 

of view that we need to continue doing the work that we are doing, 

14

working within the administration and other government agencies 

but also with foreign counterparts, to have a unified front utilizing 

authorities under the United Nations to take joint action, coordinating fully with local law enforcement authorities, but continuing 

our current efforts. 

Senator AKAKA. My time is up, Mr. Newcomb, but I noted that 

your written statement discusses a terrorist supporter identification program that has been developed with the Pacific Command. 

Given that Hawaii is the gateway to and from the Pacific, this is 

of interest, of course, to me, and I certainly want to hear more 

about that. 

My time is up, but I wish to learn more about that project. 

Mr. NEWCOMB. Fine, Senator. I would be happy——

Senator SPECTER. Thank you, Senator Akaka. Chairman Collins. 

Chairman COLLINS. Thank you very much, Senator Specter. 

Mr. Newcomb, I want to make sure that the Committee understands how you compile the list of suspected terrorist financers. 

First of all, it is my understanding that the Office of Foreign Assets 

Control has the power to recommend that individuals and entities 

that are involved in financing acts of terrorism can be placed on 

a government list, and the listing of that individual or entity is 

critical to depriving them of the ability to provide funds for terrorists. Is that accurate? 

Mr. NEWCOMB. That is accurate. I would also point out and add 

that we also are the implementing and enforcement agency as well. 

So it is those two nodes, a recommending function and an implementation function. 

Chairman COLLINS. And after your office recommends an entity 

for listing, that recommendation is then reviewed by an Interagency Policy Coordinating Committee that you referred to in your 

discussions with Senator Specter. Is that correct? 

Mr. NEWCOMB. That is correct, Madam Chair. 

Chairman COLLINS. Have you ever recommended that an entity 

be listed and had that recommendation rejected by this Interagency 

Policy Committee? 

Mr. NEWCOMB. We have made numerous recommendations on a 

variety of different targets, as is our responsibility. And it goes to 

the Policy Coordinating Council which has a multitude of different 

points of view—State Department, the Justice Department, the 

FBI, the CIA, and others. So long as there is a responsible action 

to be taken, designation per se is not the only possible tool within 

the President’s ambit of foreign policy——

Chairman COLLINS. And I understand that, that there may be 

other ways to approach the problem. But I assume that when you 

recommend the listing of an entity, that is based on an investigation that you have conducted and that there is a sound factual 

record for the listing of the entity, that is why you brought that 

recommendation forward. Is that correct? 

Mr. NEWCOMB. That is correct. When we have a target we wish 

to designate, we develop evidence so that, should a designation 

happen, we are able to sustain a challenge to that in Federal court. 

So we do develop evidentiary packages as the basis for recommendations. 

15

Chairman COLLINS. And it is correct—and I understand there 

may be other action taken, but it is correct that your recommendations are sometimes turned down by this interagency committee, 

correct? 

Mr. NEWCOMB. The issue I think we are having somewhat of a 

debate about is the characterization of ‘‘turned down.’’ Turned 

down——

Chairman COLLINS. For listing on the terrorist financers list. 

Mr. NEWCOMB. Oftentimes they are not adopted for purposes of 

listing at this time. 

Chairman COLLINS. That is the same as being turned down, not 

adopted, not—entities that you recommend be listed are not always 

listed as a result of the committee, the interagency committee, not 

accepting your recommendation that they be listed. Is that correct? 

Mr. NEWCOMB. That is correct, but I have to add the caveat that 

because there are other agencies—for example, the FBI may say we 

have law enforcement equities in that particular target at this 

time. If you move forward now, you will disrupt those equities. 

That is, in my opinion, and in the opinion of the PCC, a very responsible way to proceed. Let us not interfere with your case. We 

will stand down until an appropriate time. And there have been examples when that objection has been removed. 

Chairman COLLINS. What percentage of your recommendations to 

list Saudi entities or individuals have been rejected? 

Mr. NEWCOMB. Madam Chairman, I don’t have the answer to 

that information. You sent that to——

Chairman COLLINS. We have asked for that, as you know. 

Mr. NEWCOMB. You have asked for it, and we will get it to you 

for the record. 

Chairman COLLINS. Would you say that more than 50 percent of 

the recommendations that you have made to list Saudi entities or 

individuals have not been accepted by the committee? 

Mr. NEWCOMB. I am going to have to get that information for you 

for the record. I don’t have it at this time. 

Chairman COLLINS. In conversations with staff, you were asked 

whether it might be as high as 95 percent. Do you recall telling the 

staff that you did not believe it was quite that high? 

Mr. NEWCOMB. Yes, I certainly did say it wasn’t that high. I don’t 

have the exact figure. Let me also explain to you, there are a range 

of specific areas where we have been looking where there are considerable other equities at stake. I think the point that has to be 

made is that there are a whole range of targets that we are prepared to move forward on, can move forward on, have developed 

evidentiary packages on, and other equities come into play that are 

responsible equities. 

I don’t know if the number in every one of these categories is 

that high, but we do a thorough examination of potential targeting. 

Chairman COLLINS. One final question on this area, since my 

time has expired. On this interagency committee, as you point out, 

there are representatives from various departments and agencies 

like the FBI, departments like the State Department and Justice. 

Which agency is responsible for most of the rejections of your recommendations to list Saudi entities and individuals? 

16

Mr. NEWCOMB. I would say it is a combination of deferring action 

based on recommendations from the State Department, the FBI, 

the Justice Department, and the intelligence community based on 

a variety of equities that they have involved—diplomatic, law enforcement, intelligence, and others. 

Chairman COLLINS. So no one agency or department on the committee is responsible for rejecting your recommendations more than 

any other agency or department? 

Mr. NEWCOMB. I think in all conversations relating to foreign 

policy and foreign relations, we look very strongly to the State Department, and the State Department is always a very active player 

in these. So they do have a view, as well as the other agencies. But 

I think it is a combination of all of those. 

Chairman COLLINS. Thank you. 

Senator SPECTER. Thank you very much, Senator Collins. Senator Lautenberg. 

OPENING STATEMENT OF SENATOR LAUTENBERG 

Senator LAUTENBERG. Thank you, Mr. Chairman. 

There are things that concern me—and I want to examine the 

specifics. Unfortunately, we are pushed for time, and I look at the 

clock and realize that you have another panel, Madam Chairman, 

and we have to get on with it. But I do want to say I have an active interest in the relationship with Saudi Arabia. In 1991, immediately after the first Gulf War, I went to Saudi Arabia, and I was 

outraged at diplomats, Senators, and Congressmen with an Israeli 

stamp on their passports were prohibited entry. And I got the 

Saudis to change that in a hurry, and it is no longer a restriction, 

that is, for officials of the U.S. Government. But I think if you are 

an ordinary citizen of this great country, you are prohibited entry 

if you have had an Israeli stamp in your passport. 

It is outrageous. When they dial 911, we answered the phone immediately, sent over 500,000 people to the area to try and provide 

a rescue operation and the resuscitation effort, because that is 

what I specifically want to call it. All was lost there, Kuwait, Saudi 

Arabia, and then the ingratitude of the Government of Saudi Arabia not to present a witness here, not to present someone to offer 

testimony. Very frankly, it is compounded even to a more aggravating degree when the President has refused to permit the full 

record established in the 900-page report to be out there when the 

Saudis themselves say they would like to clear the record. Or are 

we looking at a sleight of hand, forgive the suspicion, that a routine was set up that said, well, OK, we in the Saudi Government 

will say make it public, and, Mr. President, we would thank someone in the administration if they would simply say that it is being 

withheld for methods, etc. It is pitiful. 

I am using this time knowledgeably, Mr. Chairman, and I would 

like to ask Mr. Pistole for a short view on the Saudi Government’s 

willingness to cooperate in investigations subsequent to terrorist 

attacks on the embassies in Africa and the USS Cole? 

Mr. PISTOLE. Subsequent to those two incidents, Senator, as I 

think you are aware, there was very limited cooperation from the 

Saudi Government. As I mentioned in my opening statement, I believe May 12 was the defining moment for the Saudis in that the 

17

fact that they were attacked, that Saudi citizens were killed in the 

attacks, and that al-Qaeda seemed to be thumbing their noses at 

the royal family to say we will conduct attacks in the homeland 

here and you can not stop us. The cooperation since May 12 on the 

Riyadh bombings, as I mentioned, has been unprecedented in all 

areas but for the financing issue, which is still ongoing, and there 

are a number of issues on the table for that. 

Senator LAUTENBERG. So there is still a reluctance to open up 

the relationship and to say, ‘‘America, you are without a doubt our 

best and most needed friend.’’ I find that more than just a curious 

response to this kind of symbiotic relationship that we have had for 

a long time. 

I yield back the time here. 

Senator SPECTER. Thank you very much, Senator Lautenberg. 

Senator Coleman. 

OPENING STATEMENT OF SENATOR COLEMAN 

Senator COLEMAN. Thank you, Mr. Chairman. 

Following up on the questions from my distinguished colleague 

from New Jersey on the level of cooperation, first let me backtrack 

a little bit. I believe in the written testimony of Mr. Winer, one of 

the subsequent panelists, he noted that, ‘‘Saudi Arabia has been 

the most significant source of terrorist funds for al-Qaeda.’’

Mr. Pistole, would you agree or disagree with that assertion? 

Mr. PISTOLE. I would at this point say the FBI does not have 

enough intelligence or law enforcement information to agree or disagree with that. There is obviously a tremendous amount of money 

that has flown through NGOs and charitable organizations. As Mr. 

Newcomb mentioned, the question is how much of that has gone 

specifically for terrorist activity. And in limited situations, we can 

document that, and I can tell you affirmatively, yes, that this 

money has gone for this act. But to trace it from the government 

to a particular terrorist, I can not sit here and tell you that has 

been done. 

Senator COLEMAN. Mr. Newcomb, could you respond to that? 

Mr. NEWCOMB. I agree with my colleague from the Bureau. We 

are aware of large amounts of money going to charitable organizations. They are dual purpose in the fact that some of the otherwise 

legitimate activities are subverted. The extent to which that takes 

place is not completely clear, but I would characterize it as considerable. 

Senator COLEMAN. Mr. Pistole, on the issue of financing, you indicated at least in the willingness to cooperate there has been substantial improvements in some areas but still work to be done on 

the financing side. Can you identify two or three things that need 

to be done that aren’t being done today? 

Mr. PISTOLE. Yes, Senator, several areas. One is the Saudi Government payment of defense counsel, for example, here in the 

United States of Saudi citizens who have been charged with 

crimes. That is an issue that we have raised with the Saudi Government and pursuing next week in follow-up meetings. To us, that 

is tantamount to buying off a witness, if you will, and so that gives 

us concern if the government is supplying money for defense counsel. 

18

Other areas that we are addressing is the specific funding 

through whether it is NGOs or charitable organization, that they 

know or should know is going to specific terrorist organizations or 

individuals associated with terrorism. 

Senator COLEMAN. Again, short questioning periods. I am going 

to switch gears for a second, and I apologize I wasn’t here for your 

oral testimony, but I read your written testimony. You give a very 

spirited defense of the PATRIOT Act, which has certainly been the 

source of a lot of discussion. 

Can you help me connect the dots? Is there something in the 

PATRIOT Act that you didn’t have before that specifically allows 

you to break an organization that was doing something it shouldn’t 

be doing? 

Mr. PISTOLE. Absolutely, Senator. The most compelling part of 

the PATRIOT Act has been the elimination of what we refer to as 

‘‘the wall’’ between law enforcement and intelligence collection activities. For example, if Mr. Newcomb was an FBI agent sitting in 

New York working a criminal investigation on Osama bin Laden, 

and I was an intelligence agent, because of prohibitions under ‘‘the 

wall,’’ we would not be allowed to share that information. With the 

passage of the PATRIOT Act, we are now able to share that information and ‘‘connect the dots.’’ That is the most compelling part of 

the PATRIOT Act. 

Senator COLEMAN. Does that break in the wall also go down to 

the level of local sheriffs, local law enforcement? And let me explain why I ask. There has been concern raised about crop dusters 

and the ability to spread, for instance, something like anthrax. And 

I know the FBI often has been notified about that, but I wonder 

if our local sheriffs—they know where the grass fields are. They 

know where the crop dusters are. 

Mr. PISTOLE. Absolutely, and this week, in fact, with tomorrow’s 

deadline, our Joint Terrorism Task Forces are going back and recontacting all those individuals we contacted after September 11 to 

see if there has been any suspicious activity. 

To answer specifically your question about sharing with local and 

State law enforcement agencies, that is done primarily through the 

Joint Terrorism Task Forces, and obviously it is a matter of, if 

there is classified information, whether they have the appropriate 

clearances. We still pass the information of the threat related but 

just may not identify the source or method of acquiring that information, for example, overseas. 

Senator COLEMAN. Thank you. Thank you, Mr. Chairman. 

Senator SPECTER. Thank you, Senator Coleman. Senator Levin. 

OPENING STATEMENT OF SENATOR LEVIN 

Senator LEVIN. Thank you, Mr. Chairman. Just very briefly a 

few comments, and then my questions. 

Saudi behavior towards terrorism, particularly towards terrorism 

aimed at the United States, has been very lax and very disturbing 

for many years. The reference has already been made to the attack 

on Khobar Towers in Saudi Arabia in 1996 where we lost 19 American servicemen, after which the FBI complained that Saudi officials failed to cooperate with the United States probe and denied 

requests to question key Saudi officials. 

19

During the 1990’s, the Saudi Government became one of the few 

governments in the world that supported the Taliban, despite the 

Taliban’s link to terrorists. 

At the same time the Saudi Government was taking steps to 

strengthen its relations with the United States, it is said, it was 

funding extreme Muslim clerics in educational schools, the 

madrassas, that routinely called for attacks on the United States 

and hatred of all things American. And those madrassas in Pakistan, funded mainly by Saudi money, have provided recruits for the 

Taliban. 

Anti-American statements became standard fare in Saudi-supported newspapers and publications. In 2001, after the September 

11 attack killed 3,000 people in the United States, we found out 

that 15 of the 19 hijackers were Saudi nationals. 

The recently released report by the joint inquiry on the September 11 attack states in the unclassified section that a Saudi citizen employed by the Saudi Civil Aviation Agency paid many of the 

expenses of two of the hijackers and ‘‘had access to seemingly unlimited funding from Saudi Arabia.’’

Until recently, Saudi Government officials and prominent Saudi 

citizens routinely contributed huge sums to Muslim charities which 

supported terrorism, including support for families of terrorists. 

The United States finally shut down several of those charities 

which were operating in the United States. 

The question that the President asked not too long ago—‘‘Are you 

with us or against us in the war on terrorism?’’—in the case of the 

Saudis has got to be answered, ‘‘Yes.’’ Both. The rhetoric is that 

they are with us, but the actions too often have been that, in fact, 

they have been against us. And, of course, there is now a new issue 

with U.S.-Saudi relations, and that is that 28-page piece of the 

September 11 joint inquiry report which has been redacted, 

blanked out. These deletions have been described by the former 

chairman of the Intelligence Committee, Senator Shelby, as being 

related to embarrassing information and not to information which 

should be properly classified. And it seems to me that there just 

has to be declassification of all or almost all of that material if we 

are going to make public what is in there which is so critically important. 

[The prepared opening statement of Senator Levin follows:]

PREPARED OPENING STATEMENT OF SENATOR LEVIN 

Terrorists need money to carry out acts of terrorism. They need money for explosives, for communications, for travel, and for all the other details involved in carrying out plans for mass murder and mayhem. Global terrorist organizations need 

global financing. They need to be able to transfer funds across international lines, 

move money quickly, and minimize inquiries into their finances, their activities, and 

their supporters. 

Since the 9-11 attack, stopping terrorist financing has become a U.S. priority. 

This Committee has contributed in a significant way to that priority through a 3-

year anti-money laundering investigation conducted by our Permanent Subcommittee on Investigations. This investigation, which produced extensive hearings 

and reports, not only documented little known methods for transferring illegal funds 

into the United States, but also provided important recommendations for strengthening U.S. laws to detect, prevent, and halt terrorist financing. These recommendations were included in S. 1371, a bipartisan bill I introduced in early 2001; they 

were picked up by the Senate Banking Committee which improved and expanded 

20

them; and they were then included in Title III of the USA Patriot Act, which was 

enacted into law in October 2001, six weeks after the 9-11 attack. 

The new anti-money laundering provisions in Title III of the Patriot Act boosted 

U.S. efforts to stop terrorist financing. For example, Title III tightened the rules for 

money transfers by completely barring foreign shell banks from opening U.S. financial accounts, making it harder for offshore banks to arrange transfers of money into 

the United States, and requiring U.S. banks and securities firms to exercise more 

care before opening accounts for foreign persons and financial institutions. Title III 

also targeted informal money transfer systems, called ‘‘hawalas,’’ which are often 

used in the Middle East to transfer funds outside normal banking channels without 

paperwork or regulatory oversight. The new law essentially requires these operations to register with the U.S. Government or risk shutdown and criminal prosecution. 

Title III also made it easier to prosecute money laundering offenses involving foreign offenders by making it easier to freeze and seize foreign funds, obtain information from foreign jurisdictions, and prosecute foreign individuals and companies. 

The new law also required more U.S. financial institutions to establish ant-money 

laundering programs, verify customer information, and report suspicious financial 

transactions. Title III also modernized U.S. anti-terrorism criminal statutes by making it a crime to bring into the United States or take out of the United States large 

amounts of cash without disclosing the action and, if asked, providing an explanation for the funds, and by making it clear that anti-money laundering prohibitions 

apply to funds obtained legally if intended for use in planning, committing or concealing a terrorist act. The new law has enabled U.S. prosecutors to apply anti-terrorism prohibitions to funds legally collected by a charity if that charity intends to 

use the funds to support terrorism. 

The U.S. Government has started to make good use of these new anti-money laundering provisions to intensify the fight against terrorist financing, but it would be 

incorrect to say that the United States has yet won this fight. We will hear testimony today about the difficulties of shutting down terrorist financing when some 

foreign governments are reluctant to take the necessary steps and may even, directly or indirectly, support persons or entities facilitating the movement of terrorist 

funds. 

The example the Committee has chosen to highlight today is Saudi Arabia. For 

years, there has been disturbing Saudi behavior regarding terrorism. In 1996, for 

example, after bombs killed 19 U.S. servicemen at Khobar Towers in Saudi Arabia, 

the FBI complained that Saudi officials failed to cooperate with the U.S. probe and 

denied requests to question key Saudi suspects. Also during the 1990’s, the Saudi 

government became one of the few governments in the world to support the Taliban 

in Afghanistan, despite its links to terrorists. The Saudi government also funded 

some extreme Muslim clerics and schools known as madrassas that routinely called 

for attacks on the United States and hatred of all things American. Madrasses in 

Pakistan, funded mainly by Saudi money, provided recruits for the Taliban. 

Anti-American statements became standard fare in some Saudi-supported newspapers and publications. In 2001, after the 9-11 attack killed more than 3,000 people in the United States, it was determined that 15 of the 19 hijackers were Saudi 

nationals. The recently released report by the Joint Inquiry into the 9-11 attack 

states in an unclassified section that a Saudi citizen employed by the Saudi civil 

aviation agency paid many of the expenses of two of the hijackers, and ‘‘had access 

to seemingly unlimited funding from Saudi Arabia.’’

Saudi government officials and prominent Saudi citizens have routinely contributed millions of dollars to Muslim charities which support terrorism, including supporting families of terrorists killed in bombings or other terrorist attacks. The 

United States finally shut down several such charities that were operating in the 

United States. The United States also decided earlier this year to vacate its military 

posts in Saudi Arabia at least in part due to discontent within the country at having 

a U.S. presence and continuing attacks on the United States by some Saudi clerics 

and in some Saudi publications. 

There are some recent actions taken by the Saudi government to stop terrorism. 

Saudi officials have openly identified their country as a strong U.S. ally and a foe 

of anti-American terrorism. In May of this year, after terrorist suicide bombings in 

Saudi Arabia killed 35 people, the Saudi government began a series of raids to arrest terrorists within its borders. One such raid in July reportedly resulted in the 

arrest of 16 persons linked to al Quaeda and the dismantling of a weapons arsenal 

with 20 tons of bomb-making chemicals, detonators, rocket-propelled grenades, and 

rifles. Saudi officials also allegedly used information uncovered in this raid to halt 

several terrorist plots. We will also hear testimony today that the Saudi government 

21

has taken steps to strengthen cooperation in terrorist financing cases and other 

anti-terrorism efforts. 

Today, there is a new irritant in U.S.-Saudi relations. It arises from the 28-page 

gap and other blanked out information in the 9-11 Joint Inquiry report. These deletions have been described as based less on protecting U.S. national security than 

on protecting Saudi Arabia from embarrassment. The former head of the Senate Intelligence Committee, Senator Richard Shelby, recently said, for example, that he 

had closely reviewed the deleted information and ‘‘90 to 95 percent’’ involved simply 

‘‘embarrassing’’ information that should be declassified and disclosed. Recently, the 

Saudi government itself called for declassifying the information. Disclosure is the 

right course to set the record straight. 

The evidence of the past few years indicates that Saudi Arabia has a mixed record 

when it comes to stopping terrorism aimed at the United States. Some of the 

madrassas and some of the government-controlled press continue to teach hatred of 

Americans and the United States. Some Saudi nationals, including Osama bin 

Laden, have led terrorist organizations focused on U.S. destruction. Some Saudisupported charities collect money that supports anti-U.S. terrorism. Some Saudisupported clerics continue to praise suicide bombings that kill Americans. 

The overly simplistic question of President Bush—‘‘Are you with us or against us 

in the war on terrorism?’’—is seemingly answered ‘‘yes’’ in the case of Saudi Arabia. 

The disturbing question remains: Is Saudi Arabia, in too many cases, failing to take 

the actions needed to cut off terrorist funding and failing to encourage tolerance and 

moderation rather than the hatred and extremism that breeds new terrorists.

Senator LEVIN. My question of you, Mr. Newcomb, is the following: You have indicated that the recommendations that your 

Department has made relative to listing of entities that have contributed or have links to terrorist organizations in a number of 

cases were not accepted. And you have declined to identify the organizations, those charities and other entities that you recommended. On what basis do you decline to share with us those 

recommendations? Are you asserting Executive privilege here this 

morning? 

Mr. NEWCOMB. No, Senator, I am not. 

Senator LEVIN. Then what is the basis for your refusal to share 

with this Committee the names of those entities that you have recommended? 

Mr. NEWCOMB. Let me be real clear about what it is we have 

done. We have looked at evidence or information we believe was 

credible, and we have surfaced the target to a Policy Coordinating 

Committee chaired by the Treasury Department to determine what 

action is appropriate, whether it be designation, law enforcement, 

intelligence, or diplomatic. A number of agencies have come forward in a variety of different contexts and recommended that action be deferred. 

As to the specific names, it is matters that are sensitive because 

of law enforcement or other equities that are at stake. If you wish 

to have a briefing in a classified session, that would be more appropriate. But today, in a public hearing, it is not appropriate to mention actions that we may be taking to subvert the element of surprise or to in any way interfere with ongoing diplomatic, law enforcement, or other actions. 

Senator LEVIN. Is that information classified? 

Mr. NEWCOMB. Oftentimes——

Senator LEVIN. No, not oftentimes. Specifically, are the names of 

the entities that you have recommended for listing classified? 

Mr. NEWCOMB. The evidentiary packages we prepare in most instances are. 

22

Senator LEVIN. Now let me ask my question again. My time is 

up? I will still ask it one more time, if I may, Mr. Chairman. I 

know the Chairman tried very hard and others have tried very 

hard to get this information, so let me try again. 

Are the names of those entities classified? The names classified 

that you have recommended for listing. It is a yes or no question. 

Mr. NEWCOMB. The names themselves are not classified. 

Senator LEVIN. Then I think you ought to present them to us 

today. 

Mr. NEWCOMB. I don’t have them with me, Senator. 

Senator LEVIN. I think you ought to present them to the Committee within the next 24 hours if they are not classified, unless 

you are asserting Executive privilege that the President only can 

assert. 

Thank you. 

Senator SPECTER. Thank you, Senator Levin. When I passed you 

the note that the time was up, I was enjoying your questioning, not 

so much the answers but the questioning. But we have got a lot 

of Senators here and another panel. 

Senator LEVIN. I appreciate that. 

Senator SPECTER. Thank you. Senator Pryor. 

OPENING STATEMENT OF SENATOR PRYOR 

Senator PRYOR. Thank you, Mr. Chairman. 

I have a question first for Mr. Pistole, and that is, have you 

found Saudi Arabia in general to be cooperative with your agency? 

Mr. PISTOLE. There is a clear delineation between prior to May 

12 and the bombings in Riyadh and after May 12. Prior to May 12, 

there was a lot of frustration. Several Senators have mentioned 

Khobar Towers, tremendous frustration with that. Since the May 

12 bombings where Saudi citizens were killed, and U.S. citizens 

were killed, there has been, as I described it, unprecedented cooperation. 

Senator PRYOR. When you say unprecedented, do you feel like it 

is totally transparent cooperation, or do you feel like they are still 

holding some things back? 

Mr. PISTOLE. Oh, clearly, I believe they are holding some things 

back, just as I think we would in any investigation if we have the 

Mabahith come here to conduct an investigation because Saudi citizens were killed. We would not share everything with them because of national security concerns. So I don’t for a minute doubt 

that they are withholding some information, what they perceive as 

in their national security interest. But the level of cooperation that 

we have had is such that, for example, having direct access to 

interview Saudi citizens who were eyewitnesses, direct access to 

the evidence, to bring back to the FBI laboratory if we so desired 

to do any type of analysis we wanted, that is what I describe as 

unprecedented. 

Senator PRYOR. Mr. Newcomb, I would ask you the same question, and that is, the level of cooperation from Saudi Arabia to your 

agency. 

Mr. NEWCOMB. Yes, we have achieved a number of successes. 

One was the joint designation of two branches of the Al-Haramain 

charitable organization in Bosnia and Somalia, as well as an indiVerDate 0ct 09 2002 08:39 Jan 30, 2004 Jkt 089039 PO 00000 Frm 00026 Fmt 6633 Sfmt 6601 C:\DOCS\89039.TXT SAFFAIRS PsN: PHOGAN
23

vidual that was affiliated with one of the charities, Mr. Julaidan. 

At meetings that we participated bilaterally with the Saudis, they 

announced to us and then subsequently announced in a press release the creation of a ministry specifically for the oversight of 

charities. In discussions we had with the Jeddah Chamber of Commerce, they implemented a code of conduct relating to standards 

for charitable giving. And we have had dialogues with a variety of 

deep-pocket Saudi individuals going through the responsibilities 

that we believed they were presented in the sanctions initiative 

and the United Nations resolutions. 

We have had meetings in Saudi and here, people soliciting us 

and us soliciting them. So those are things I would point to of 

things we have been able to do together, Senator. 

Senator PRYOR. Thank you. I would also join with Senator Levin, 

Mr. Newcomb, that if the names are not classified, I think you 

should provide those to the Committee, hopefully within the next 

24 hours. 

The last thing I wanted to ask—this is a general question probably for both of you, and that is, as I understand Saudi Arabia, 

there are a lot of internal pressures relating to terrorist activity, 

and perhaps the government does not either have the will or in the 

final analysis maybe the total control over some terrorist activities 

that may be going on within its borders. And as I understand it, 

the royal family there has been subject to acts of terrorism and 

near acts of terrorism on a number of occasions. 

Has that changed since—you were talking about May 11? I have 

forgotten the date. 

Mr. PISTOLE. May 12. 

Senator PRYOR. Has that changed since May 12? 

Mr. PISTOLE. I believe so because I think that the royal family 

in particular sees themselves as being vulnerable to al-Qaeda efforts in the kingdom and that no longer is this simply an entity 

that is focusing on Western interests but has now turned on the 

kingdom and the royal family that represents the kingdom. So, yes, 

I think they see themselves in a struggle for survival at this point. 

Senator PRYOR. Mr. Newcomb, do you have any comments on 

that? 

Mr. NEWCOMB. I don’t. I have not had discussions since that date 

so I could base any summary or conclusions, so I cannot add to 

that. 

Senator PRYOR. Thank you. That is all, Senator Specter. Thank 

you. 

Senator SPECTER. Thank you very much, Senator Pryor. 

Mr. Pistole and Mr. Newcomb, there are obviously many more 

questions to be asked, but we have another panel. What we would 

request that you do is stay in the hearing room because something 

may arise in the course of the testimony from the next panel which 

would lead us to want to ask you some follow-up questions, if that 

should arise. 

We will now turn to Dore Gold, former Israeli Ambassador——

Senator CARPER. Mr. Chairman, could I ask one quick question 

of these panelists before they leave? 

Senator SPECTER. One quick question? 

Senator CARPER. Yes. 

24

Senator SPECTER. With an answer? 

Senator CARPER. Hopefully. 

Senator SPECTER. OK. 

Mr. Pistole, we have had a late arrival here. Senator Carper has 

arrived and has one quick question. 

OPENING STATEMENT OF SENATOR CARPER 

Senator CARPER. Gentlemen, and Mr. Chairman, thank you for 

your consideration. 

Gentlemen, the report issued last year on terrorist financing by 

the independent task force sponsored by the Council on Foreign Relations States, ‘‘It is true that Saudi Arabia has taken two or three 

important steps to improve its capability to cooperate on these matters with the United States, for which it should be commended. A 

hundred more steps, and Saudi Arabia may be where it needs to 

be.’’

That is the quote, and that sounds like Saudi Arabia is about 1 

percent of the way where it needs to be. Is that a fair characterization? 

Mr. NEWCOMB. Senator, I would respond by saying at least from 

where we sit, Saudi has taken some important first steps, steps I 

have mentioned in answer to Senator Pryor’s questions. I think 

then the question becomes follow-up, how are they implementing, 

what are the oversight of charities that this new ministry is doing, 

what future joint designations are we going to make, and how are 

they going to be implementing the regulation of charities and other 

such activities. So I think it is an ongoing process and one that we 

need to continue. 

Senator SPECTER. Senator Carper, you have a second quick question? 

Senator CARPER. Thank you, Mr. Chairman. 

In terms of getting the other 99 percent of the way, what do we 

need to be doing at our end, the legislative end, to encourage that 

along? 

Mr. NEWCOMB. I think we need to be doing more of what we are 

doing, what we are doing except more of it, and I think we need 

to continue dialogues where we are able to focus on the issues that 

are relevant to the relationship. 

Senator CARPER. Mr. Pistole, do you want to add any comments 

on this? 

Mr. PISTOLE. My only insight on that, Senator, is that it is such 

a broad issue for the U.S. Government as a whole with so many 

equities represented that, from an FBI perspective, we are having 

some significant successes that we are trying to build upon and 

that anything that we would do would need to be done in concert 

with the National Security Council, with all the other equities represented. So we are building on the successes. We are trying to get 

into things that we have never been allowed to before, and we have 

had some incremental successes. 

Senator CARPER. All right. Thanks very much. 

Senator SPECTER. Thank you very much, Senator Carper. 

We will now proceed to the second panel. The first witness is 

former Ambassador Dore Gold, Israeli Ambassador to the United 

Nations, a recognized expert on Middle Eastern strategic affairs, 

25

1The prepared statement of Mr. Gold with attachments appears in the Appendix on page 77. 

author of ‘‘Hatred’s Kingdom: How Saudi Arabia Supports the New 

Global Terrorism.’’ Ambassador Gold, we are very tight on time, 

and we will set the clock at 5 minutes, and we look forward to your 

testimony. 

TESTIMONY OF DORE GOLD,1 FORMER ISRAELI AMBASSADOR 

TO THE UNITED NATIONS, AND PRESIDENT, JERUSALEM 

CENTER FOR PUBLIC AFFAIRS 

Mr. GOLD. Thank you very much, Madam Chairman and Senator 

Specter and the Senators who are Members of this Committee, for 

inviting me to this panel. I should start by saying my testimony 

here, I am speaking on my own behalf. I don’t represent the Government of Israel or any other institution. I think, however, that 

there are three dimensions of what Israel has experienced over the 

last number of years that will be of interest to the Committee and 

to the American people at large because of the concern about Saudi 

Arabia’s role in support, both ideological and financial, of the new 

terrorism that we are facing. 

I believe some of the lessons and some of the experiences that 

we are having have direct connections and implications for the 

issues that are of concern to you. 

Let me begin with a little bit about how we have gotten into this 

subject, and I am going to basically restrict my presentation to just 

a number of issues that are in a PowerPoint presentation. You 

have my written testimony, if you want to go into further detail on 

historical elements as well. 

If today, for example, a young Palestinian wishes to see what are 

the ideological sources on what basis he should commit a suicide 

bombing attack against Israelis, and he goes to the website of the 

Hamas organization, what you will find here—and you see it here 

on the PowerPoint. This is directly from a Hamas website. Of, let’s 

say, the number of clerics that are mentioned here who justify suicide attacks, the use of suicide bombing, and the fact that the person is regarded as a martyr in Islam, the largest national grouping 

of clerics that support these positions are Saudis. 

This immediately opened up the question of the Saudi relationship to the wave of suicide bombing that Israel is facing. But the 

problem of ideological support that we are seeing for these kinds 

of suicide attacks is not just confined to the area of Israel. 

If we go on to the next presentation, right after the September 

11 attack a book was published on a Saudi website which was rather alarming since it basically—it is called ‘‘The Foundations of the 

Legality of the Destruction That Befell America.’’ This basically 

justifies the attacks on the United States. 

Now, when you find a book like this on a Saudi website—and 

what was interesting, of course, is one of the men who is one of 

the authors of this book is mentioned on the Hamas website—you 

have to ask: Are we dealing with a Saudi extremist, someone who 

is on the periphery of society, somebody who is maybe the equivalent of a Timothy McVeigh in the Saudi system? 

Well, we did biographical research on these individuals, particularly the two that wrote the introduction to the book. One of them 

26

is Sheikh al-Shuaibi, who recently died last year, in 2002, and he, 

of course, is one of the ideological sources on the Hamas site as 

well. He happens to be an individual who grew up in the Saudi system, who studied under the Grand Mufti of Saudi Arabia when 

King Faisal was in power. His students look like a ‘‘Who’s Who’’ 

of Saudi Arabia, including the former Minister of Islamic Affairs of 

Saudi Arabia and the current Grand Mufti. And, therefore, when 

someone like this puts his name on a book justifying the attacks 

on September 11 and we find that that individual has a leading 

role in the education of elements of the Saudi establishment, that 

is a source of very serious concern about what is going on in Saudi 

Arabia in terms of religious support for the new wave of attacks 

that we are facing. 

It also has a relationship to the financial side as well, because 

if leading clerics are taking position of this radical nature, what 

does that suggest to members of society who are thinking about 

what to do about charitable contributions, and even if an organization is considered tainted because of terrorist connections? Therefore, looking into the ideological support structure of the new terrorism becomes very important. 

Just to give you a sense of where things can possibly lead, once 

you can justify attacks on the United States of September 11, it 

doesn’t become surprising that we have now a new fatwa that was 

released in May 2003 which justifies the use of weapons of mass 

destruction against the United States, including the killing of 10 

million Americans or other infidels. 

Now, the author of this particular fatwa—his name is Nasser alFahad—happens to have been imprisoned by Saudi Arabia recently, which is a positive development because I know many of the 

Senators are following the post-May 12 developments. But, nonetheless, that these ideas are out there, that these ideas influence 

young people, are of tremendous concern. And, of course, we have 

also seen in the past in the 1990’s where extremist clerics were put 

in prison by Saudi Arabia were subsequently let out. So this is an 

issue that you should be looking at. 

Let me move now into the issue of the terrorist financing with 

direct implications for your Committee and for your concerns. This 

may be difficult for you to read, but this particular element of the 

powerpoint presentation outlines the three largest Saudi charities 

that have been suspected of being involved in terrorist financing: 

IIRO, WAMY—that is the World Assembly of Muslim Youth—and 

al-Haramain. I think the important element in this particular slide 

that you should pay attention to is many times you hear in a lot 

of these hearings Saudi NGOs, non-governmental organizations. 

And you would think from that, therefore, that the government responsibility in Riyadh is somewhat minimal when you see connections between Saudi charities and particular terrorist organizations. 

But someone doing the most minimal declassified work possible, 

going to the websites of each of these organizations, in Arabic, you 

would find—when you try to see who is at the head of these organizations, what you will find is that these are not NGOs. These are 

GOs. These are government organizations, and let me be very specific. 

27

When you look to see who is the head of the IIRO, which is a 

branch or a subset of the Muslim World League, you find that the 

chairman of the Constituent Council of the World Muslim League, 

the Muslim World League, is no less than the Grand Mufti of 

Saudi Arabia, who is, by the way, a member of the Saudi cabinet. 

If you look both at WAMY and al-Haramain—I understand you 

should have before you also these papers so that you can see them 

more clearly—you will see that at the head of both WAMY and alHaramain, the chairman of these organizations, the chairman of 

the WAMY Secretariat and the chairman of the al-Haramain Administrative Council, is the Minister of Islamic Affairs of Saudi 

Arabia, who is also a Saudi cabinet member. So that the ultimate 

corporate responsibility in each of these organizations is in the 

hands of a member of the Saudi Government. 

Now, in following how these organizations have been active, 

probably one of the earliest sources of evidence of some problem in 

the way that these organizations function comes from documents 

that were found in Bosnia in the late 1980’s. One of these documents is on the stationery of the International Islamic Relief Organization, and it summarizes a meeting between bin Laden representatives and the Secretary General of the Muslim World 

League. This document is, of course, not an Israeli document. It 

wasn’t found by Israeli sources, but it is certainly well known 

among those who are following this issue in the intelligence community. 

But I think what directly relates to Israel is the following document. In Operation Defensive Shield in the West Bank, when 

Israel went into Palestinian headquarters, a number of Saudi documents were found, not just Palestinian documents, on the pattern 

of terrorist funding. This document is on stationery of the International Islamic Relief Organization, and it summarizes the disbursement of $280,000 to 14 Hamas front organizations. So here 

we have IIRO——

Senator SPECTER. Do you have a date on that document? 

Mr. GOLD. I can get the date for you, but this document was undated. We can probably approximate it in the year 2000. 

Now, what is very important, I think, for your study of this situation of Saudi financing of terrorism is to look at the statements 

that Saudi officials are making about issues which we can document. For example, Adel Jubeir, who frequently appears on American television—he is the foreign policy adviser of Crown Prince 

Abdullah—stated on August 16, 2002, on ‘‘Crossfire,’’ ‘‘We do not 

allow funding to go from Saudi Arabia to Hamas.’’ And he has 

made repeated references of this sort. On the other side, in the Foreign Ministry of Saudi Arabia, the Foreign Minister, Prince Saud 

al-Faisal told Arab News, an English newspaper of Saudi Arabia, 

the following on June 23, 2003. He was asked if the kingdom had 

ever financed Islamic movements in Palestine, meaning Hamas 

and Islamic Jihad, whether directly or indirectly. And Prince Saud 

said that since the establishment of the Palestine Liberation Organization as the sole legitimate representative of the Palestinian 

people, the Saudi Kingdom has been sending the remittances 

through the PLO. So, again, we have another firm denial of any 

Saudi Arabian support for Hamas. 

28

1The prepared statement of Mr. Winer appears in the Appendix on page 110. 

Senator SPECTER. Ambassador Gold, you are now double time, so 

could you sum up? 

Mr. GOLD. Yes. I will wrap up with one more document. 

One of the strongest sources of evidence showing Saudi Arabian 

support for Hamas, a recognized international terrorist organization, is actually a letter written by Mahmud Abbas, also known as 

Abu Mazen, the Prime Minister of the Palestinian Authority today. 

This letter was written in December 2000. It was a fax that was 

sent to Prince Salman, governor of Riyadh and a full brother of 

King Fahd. In this letter, Abu Mazen specifically requests that the 

Saudis stop funding al-Jamiya al-Islamiya, which is a Hamas front 

in the Gaza Strip. 

I would just end by showing you the kind of activities that this 

organization does, because many people say, oh, well, they are involved in civilian activity. This is a graduation of 1,650 kindergarten students in the Gaza Strip in 2001 in which the children are 

in uniforms. They are re-enacting terrorist attacks. For example, 

here is a young girl re-enacting the lynching of Israeli soldiers. 

Many of them are also wearing suicide belts as well. So this is the 

kind of education which Saudi Arabia has been funding and the 

kind of education which Abu Mazen has sought that the Saudis 

stop. 

One last element, because terrorist financing is—and this will be 

my final slide. This is a check, a corporate check from the Chase 

Manhattan Bank in New York. The corporate check belongs to AlRajhi Banking and Investment Company, which has long been suspected of being a conduit for terrorist financing by many authorities. In this case, we actually found a check from 1999 showing 

how an American account could be used for funding Hamas. The 

organization the check is written to is Lajna Sakat Tulkarm, which 

means the Tulkarm Charity Board, which is an unquestionable 

Hamas front. 

I will stop here, and we can go into further elements of my presentation. 

Senator SPECTER. Thank you, Ambassador Gold. 

The Committee had invited Adel al-Jubeir, foreign policy spokesman for the Kingdom of Saudi Arabia, to appear and he declined. 

I want that to be known publicly. 

Our next witness is Jonathan Winer, formerly Deputy Assistant 

Secretary of State for International Law Enforcement, and now an 

attorney with the firm of Alston and Bird. Thank you very much 

for joining us, Mr. Winer, and we look forward to your testimony. 

TESTIMONY OF JONATHAN M. WINER,1 ALSTON AND BIRD 

Mr. WINER. Thank you, Mr. Chairman. Before the team goes off 

to Saudi Arabia to try and work these issues out, it may be useful 

to recollect what has happened in past missions. 

Back in 1998, 5 years ago, right after the bombs went off in Dar 

es Salaam and Nairobi, the Executive Branch convened an interagency meeting on the International Emergency Economic Powers 

Act to determine whether there should be designations in connection with those bombings in relationship to terrorist finance. We 

29

tried to assess as a government then what the basis was for alQaeda to carry out its activities around the world, and we had two 

false conclusions we were basing our assessment on at the time. 

The first is it doesn’t take a lot of money to be a terrorist, and the 

second is bin Laden is wealthy and doesn’t need money from anybody else. It was an incomplete theory of the case, an inadequate 

theory of the case, and ultimately a wrong theory of the case. 

The actual case was it cost a lot of money to create al-Qaeda. It 

was a constant fundraising operation. And it took us some months 

until late 1998 to figure that out. We now had a theory. The question was what to do about it. 

What we sought to do then was to map the network with fragmented information, identify the key nodes, and then try to disrupt 

those nodes. We also had as a government the enormous power of 

the International Emergency Economic Powers Act to freeze assets 

of foreign entities—banks, businesses, charities, whatever. And we 

recognized that this important power was not recognized or understood by many countries, including countries where we saw terrorist finance to be a problem. 

We came to the conclusion that we should do an International 

Emergency Economic Powers Act designation against the Taliban 

as one way of taking action against al-Qaeda, as a means of putting pressure not only on the Taliban but their supporters, as well 

as other governments in the region. We wanted to increase the leverage that we had. 

We had had sporadic contacts at that point with embassies in the 

region, including with the Saudis. These were not particularly focused, and they weren’t particularly high level. We recognized in 

late 1998, early 1999 as a government that the only way you can 

really deal with the Saudi Government is from the top down. There 

were communications between the Vice President’s office and 

Crown Prince Abdullah which took place in which the United 

States said we want to send a team over that is very high level to 

discuss something that is very important in connection with our 

embassies having been attacked. 

In May or June 1999, these meetings took place in Saudi Arabia. 

They were interagency meetings, very similar to the interagency 

meetings that are about to take place once again in Saudi Arabia 

that have been discussed earlier today in these hearings. 

We had said we didn’t want one-on-one’s, this agency meeting 

with that agency on either side, because when you have one-onone’s agency after agency, you can get the runaround: We would 

love to help you, but you have to go talk to someone else. We wanted a unified, integrated approach government to government. That 

is my understanding of what took place. I was not directly part of 

that mission. I received reports when it came back. 

The delegation talked about IEEPA to the Saudi Government. 

They talked about how the use of IEEPA could hurt U.S.-Saudi financial and economic relationships and even result in substantial 

freezes of Saudi funds and freezes of funds of high-level individuals 

in Saudi Arabia with international prominence. These meetings 

took place 4 years ago, prior to the September 11 attacks. 

We advised them that we would be shutting down Ariana Airlines, the Taliban’s airline, and that any airports that continued to 

30

permit Ariana flights to take place, they could potentially get shut 

down. At that point, the Moscow airport and the Saudi airport 

were two of the airports that Ariana was using, given cover in part 

by the Russians. The Saudi ability—Ariana Airlines’ ability to use 

Saudi Arabia was stopped at that time, and that provided the first 

use of IEEPA in that area relevant to the terrorist area. 

We hoped that this would start a new relationship on the subject 

of terrorist finance. I left the government in late 1999. I was told 

that there was a second meeting in early 2000. Another U.S. interagency delegation went to Saudi Arabia. The readout that I hear 

on an unclassified basis very generally is that there was only marginal benefit from the second meeting, that the desert sands of 

Saudi Arabia had ground down this initiative like so many before 

it. Again, 31⁄2 to 4 years ago, prior to September 11. 

One problem we ran into was that the Saudis had very little centralized integration and their government agencies didn’t talk to 

one another, didn’t trust one another, didn’t work together, didn’t 

communicate with one another. And that had an impact on the political will of the Saudi Government. 

Now, I was asked also to talk briefly about the designation process. I participated in IEEPA designation processes on various 

issues when I was in the Clinton Administration, and I can tell you 

that, yes, sometimes it was the State Department who said no, we 

don’t want to get our foreign partners upset—not my part of the 

State Department but other parts of the State Department. And, 

of course, geographics trump functionals most of the time at the 

State Department. State relationships are more important. Sometimes it was the FBI. Quite often it was the FBI because they 

didn’t want to have criminal cases interfered with. Sometimes it 

was the Justice Department backing up the FBI. 

In my experience, it was never the CIA or the intelligence agency. It may have happened in other cases, but not in any case that 

I participated in. And very rarely—rarely—it was the White House 

or the Treasury, but very rarely. Usually State or FBI in my experience. 

Now, did we shoot down designations that Treasury had the ability to put together and, in fact, recommended? We absolutely did. 

It did not happen to be in the terrorist area during my time. It was 

in other areas. But it certainly happened, in which foreign policy 

or other considerations trumped decisions or recommendations 

made by OFAC. I can say that as a general matter. 

A couple of final points before I run out of time. It has been my 

experience that collective leadership is not usually a mechanism to 

forceful action. In the Clinton Administration, through much of the 

time a fellow named Dick Clark pushed counterterrorism in a central way, including terrorist finance. I am sure there is someone 

doing this in the administration today. I just don’t happen to know 

who it is. I am concerned that there isn’t somebody in the White 

House with that job. I think there should be. 

Finally, with regard to the Saudis and this latest mission, coming 4 years after the first mission on exactly this topic, denial is 

not just a river in Egypt, and those who forget the past are condemned to repeat it. 

Thank you, Mr. Chairman. 

31

1The prepared statement of Mr. Emerson appears in the Appendix on page 131. 

Senator SPECTER. Thank you very much, Mr. Winer. 

Our next witness is Steve Emerson, an expert on terrorism and 

terrorist financing, the author of ‘‘American Jihad: The Terrorists 

Living Among Us.’’ Mr. Emerson is currently NBC’s terrorism analyst and a special investigative correspondent for CNN. 

Thank you for joining us, Mr. Emerson, and we look forward to 

your testimony. 

TESTIMONY OF STEVEN EMERSON,1 EXECUTIVE DIRECTOR, 

THE INVESTIGATIVE PROJECT 

Mr. EMERSON. Let me clarify that I was formerly a correspondent 

for CNN. Thank you to the Committee for holding this hearing this 

morning. I think that shining a light on the whole issue of the very 

intricate web of connections between the Saudi Government and 

the funding of terrorism is absolutely pivotal to preventing another 

September 11. 

Just recently, in the last month, Adel al-Jubeir, foreign affairs 

adviser to the Crown Prince Abdullah, denied that Saudi Arabia 

was funding terrorism, and when asked about whether Saudi charities had complied with the new regulations, he said he hoped so. 

He also stated, ‘‘If the UN is headquartered in New York, is America responsible for everything the UN does?’’

Now, I think it is very important to bear out in the very beginning here that the analogy that Mr. Jubeir has referred to is not 

correct. The fact of the matter is that major Saudi NGOs, non-governmental organizations, as they have been designated legally, either in Saudi Arabia or in conjunction with the United Nations, 

have been tied for years directly and indirectly to the support for 

al-Qaeda, Hamas, Islamic Jihad, and other terrorist groups. Often, 

it must be stated, the connections are not neatly compartmentalized, largely because of the very complex ways in which terrorist 

funding has been laundered to terrorist groups. Still at other times, 

the evidence shows that NGOs carry out activities that are ‘‘totally 

legitimate and legal.’’ Indeed, it is the very external legitimacy of 

these groups that provides the perfect cover to siphon off, divert, 

or launder financial support or to provide cover for terrorist cells. 

There is also a problem sometimes in determining whether an affiliate group makes the entire organization corrupt or whether, in 

fact, there is just one bad rogue chapter in that organization. 

Let me just briefly go over some of these things that I have presented in the written testimony to give an indication of why the 

problem is not just limited to either select chapters and why it is 

connected to the Saudi regime itself. 

For example, we have collected several textbooks used and distributed in the United States, distributed by the Saudi Embassy in 

Washington, D.C. They have the full imprimatur of the Kingdom 

of Saudi Arabia on the textbooks. In the testimony, I refer to the 

curricular used in grades 4 through 11, but let me just cite a quote 

from the 7th grade class Book 5. The book says, ‘‘ ‘What is learned 

from the Hadith?’ and teaches, ‘The curse of Allah be upon the 

Jews and the Christians.’ ’’ Grades 8 through 11 continue to emphasize the notion and piousness of the jihad, and in grade 11 it warns 

32

against taking the Jews and Christians as friends or protectors of 

Muslims. 

I think this, unfortunately, helps develop a whole generational 

mind-set that leads to terrorism, noting that terrorism is really the 

culmination of indoctrination and recruitment. Much of that indoctrination is entirely legal, with terrorism being the violent, illegal 

expression ultimately and representing the culmination of the indoctrination and recruitment. 

The Muslim World League, as has been referred to previously, is 

a group that was established in 1962 by the Saudi Arabian regime. 

It has continued to fund major Islamic movements around the 

world, often defending itself by claiming it is only involved in promoting education or repelling hatred against Islam. 

However, it is absolutely clear that U.S. investigators, law enforcement for the FBI and intelligence investigators at the CIA, 

have collected abundant material showing MWL connections to alQaeda and to Hamas during the past 20 years—15 years in 

Hamas, to be specific, and in the case of al-Qaeda going back to the 

late 1980’s. Similarly, other groups in Saudi Arabia, NGOs such as 

the International Islamic Relief Organization, established in 1978 

as an arm of the MWL. Let me just briefly point out that in 1994, 

Muhammad Jamal Khalifa, Osama bin Laden’s 37-year-old brother-in-law, was arrested in California coming from the Philippines. 

In his possession were documents connecting Islamic terrorist 

manuals to the International Islamic Relief Organization, the 

group that he had headed in the Philippines. In addition, the Canadian Government has stated in testimony in Canadian courts in 

the last 2 years that the IIRO secretly funded terrorism. 

I think it is also important to note that Fayez Ahmed Alshehri, 

one of the September 11 airline hijackers, told his father before he 

set out for the hijacking conspiracy that he was going to work for 

the IIRO. 

There is another group that is also involved and controlled by the 

Saudi Government and also has been cited in terms of its ties to 

Bosnian terrorists and to al-Jemaa Islamiyah. This group is alHaramain. 

Last, I would like to point out that the group called WAMY, the 

World Assembly of Muslim Youth, is an organization that, even 

though Saudi officials claim have no official connection, is largely 

funded by Saudi officials and by senior Saudi philanthropists. This 

organization has been tied to the 1993 World Trade Center bombing and has been repeatedly tied to al-Qaeda in numerous activities 

around the world. Most of that material I submit for the record in 

the testimony. 

Thank you very much. 

Senator SPECTER. Thank you, Mr. Emerson. 

I had asked FBI Official Pistole to stay, and I have one question 

for you at this point as a follow-up to Mr. Winer. Is Mr. Pistole 

present? 

Mr. LORMEL. I am Dennis Lormel, sir. Mr. Pistole had to go back 

to the office. I stayed behind. I am chief of the Terrorist Financing 

Operations Section. 

Senator SPECTER. Well, when we ask witnesses to come, we request that they stay for the full hearing because in the course of 

33

the hearing other issues arise where we would like to have them 

here. 

Mr. LORMEL. Sir, that is why I stayed. If I could answer the 

question, I would be happy to. 

Senator SPECTER. Well, when the Committee asked Mr. Pistole 

to stay, he ought to stay. In his absence, I will ask you the question. 

It has been reported that the FBI will not pursue a criminal investigation where probable cause exists for the investigation if 

there is an objection from the State Department. Is there any validity to that report? 

Mr. LORMEL. No, sir, I don’t believe so. Maybe if you could explain a little more, I could better understand the context. 

Senator SPECTER. Well, the report is that where there is probable 

cause to pursue an investigation under the criminal laws of the 

United States, the State Department can interpose an objection 

and prevent that investigation from going forward. And that is a 

very relevant point of inquiry at this particular hearing. It is a 

point that I have inquired about before. 

Would you do two things? Would you identify yourself for the 

record? Do that now. 

Mr. LORMEL. Dennis Lormel, and I am the chief of the Terrorist 

Financing Operations Section in the Counterterrorism Division of 

the FBI. 

Senator SPECTER. OK. And would you relay that question to 

higher authorities in the Federal Bureau of Investigation and respond to this Committee? 

Mr. LORMEL. Yes, sir, I will. 

Senator SPECTER. Thank you. 

Mr. LORMEL. And to my knowledge, I am not aware of any such 

cases. I can specifically speak to terrorist financing, and in our investigations there has been no such interaction with the State Department requesting that we stand down on criminal cases. 

Senator SPECTER. Well, take the question up with higher authorities in the FBI, and while you are doing that, tell them that 

when the Committee asks a witness to appear, we like to have 

them here for the entire hearing, like the Senators are here for the 

entire hearing. 

Mr. LORMEL. Yes, Senator. 

Senator SPECTER. Mr. Winer, you very delicately stated that the 

State Department doesn’t want to get our foreign partners upset. 

That is a magnificent understatement. Have you ever heard of a 

report that the FBI would not pursue an investigation, a criminal 

investigation, where probable cause existed if the State Department raised an objection at the highest levels? 

Mr. WINER. I have not heard such reports, sir. In the time that 

I was at the State Department as the senior person for international law enforcement, I was aware of no such request from the 

State Department to the Bureau. Certainly I made none or would 

have encouraged or permitted the making of none. 

However—and it is an important caveat—when requests of that 

nature are made, they are not written down and they are not done 

within the system, and they are done at a high level. I don’t mean 

this specific request because I don’t know of such a request. But 

34

if a foreign government wished to be protected from a particular action by the U.S. Government and a Secretary of State so chose to 

do it, they do have the capacity and, in my experience, take advantage of that capacity to go around the system on any number of 

highly sensitive matters to arrange to have things done. 

I think it is very undesirable because I believe every decision 

made should be on the record. I believe it is critical for the integrity of the system not to have decisions taken off the record. But 

it did take place during my time in government, not in connection 

with the FBI, not in connection with a criminal justice matter. 

Senator SPECTER. Well, what was it in connection with and what 

was it? 

Mr. WINER. Inquiries that other people were making other than 

the FBI. Matters were essentially calmed, quieted, stopped as a result of very high-level interventions, but not criminal justice pertaining to terrorism, not law enforcement per se. Regulatory. 

Senator SPECTER. Can you be a little more specific in 12 seconds? 

Mr. WINER. I can not, not because I am trying to protect any information from the Committee but because while I recollect it happening more than once, the exact circumstances are not at my fingertips, unfortunately. The memory of it is absolutely precise, but 

the substance, unfortunately, is not, sir. 

I will say last, if I may, that in the regulatory review process, 

the fact that there is no process for integrating the equities into a 

solution is a huge problem when it comes to IEEPA. And, generally 

speaking, the way in which the Bureau deals with the State Department is that simply the Bureau does its thing, the State Department does its thing, and never the twain shall meet. So the 

problem is, when you get into everyone asserting their equities 

within the interagency process for an IEEPA designation, if one 

component objects, often that terminates, shuts down the whole 

thing, and that is not a good outcome. 

Thank you, sir. 

Senator SPECTER. Well, there is considerable concern by many in 

the Congress about Saudi Arabia being shielded for foreign policy 

reasons. 

Mr. WINER. I have that concern, sir. 

Senator SPECTER. That has been broadly expressed here today 

and in virtually every quarter. And one of the inquiries which has 

to be pursued is to what extent that is done and what are the policy ramifications, and it may be appropriate on public policy lines. 

But when you have a criminal investigation, an investigation into 

the U.S. Criminal Code, and there is probable cause to proceed, 

and it does not proceed because of foreign policy considerations, 

that is a matter which should attract the attention of the Congress 

at the highest levels. And that is an issue which is being pursued. 

It is not an easy issue to get answered. 

Chairman Collins. 

Chairman COLLINS. Thank you very much, Senator Specter. 

Ambassador Gold, your exhibits are extremely persuasive and 

convincing in casting much doubt on the repeated claims by the 

Saudi Government that it is not funneling money to terrorist 

groups such as Hamas. Our previous FBI witness believes that 

35

there has finally been a sea change in the commitment of the 

Saudis since the bombing in May in Riyadh. 

I want to ask you two questions. First, what is your general assessment of the commitment by the Saudis in the wake of the May 

bombing? Do you believe there really is an attitude change and a 

commitment now? And, second, have you seen any evidence that 

the May 12 bombings have caused the Saudis to cut back on their 

financial and other support for Hamas? 

Mr. GOLD. Let me answer your question, Madam Chairman. I 

think one has to draw a fundamental distinction between what is 

going on domestically in Saudi Arabia and what might be going on 

globally. Certainly that is the evidence that I have at this point. 

I think it is clear, anybody just perusing newspapers since May 

12, that Saudi Arabia is taking a large number of counterterrorist 

actions at home in terms of unveiling different units of al-Qaeda 

or—and, by the way, in geographically different parts of the kingdom—or trying to find weapons caches. That seems to be what is 

going on there. Counterterrorism activity at home seems to be considerable in comparison to what existed before. 

However, I can report to you with, let’s say, full authority and 

perhaps even encapsulating the national intelligence assessment of 

Israel that at present, as we speak, approximately 50 to 70 percent 

of the Hamas budget comes from Saudi Arabia. And I would say 

that portion, the Saudi portion of Hamas funding, is growing rather than declining. 

Now, that is all I can say about the particular case of Saudi Arabia and Hamas. I think it would be interesting to compare what 

is going on globally in the Philippines, in Russia, in East Africa, 

and with respect to al-Qaeda as well outside of Saudi Arabia to see 

whether their action is only aimed at protecting themselves domestically, but it is basically the same old business overseas. 

Chairman COLLINS. Thank you. 

Mr. Emerson, you raised a very good point in your statement 

that it is not only a matter of Saudi support, financial support for 

terrorist organizations but, rather, the curriculum, the schools, 

what Saudi children and Saudi-supported schools elsewhere are 

teaching young people and whether or not they are instilling a hatred of Christians and Jews. And to me that is equally disturbing 

because it helps raise a whole new generation of people who are 

going to be susceptible to terrorists, to involvement with terrorist 

groups. 

Have you seen any change in Saudi schools since the events of 

September 11 or more recently since the bombing in Riyadh? 

Mr. EMERSON. Since September 11, I can tell you Saudi officials 

have declared that they have reined in some of the clergy and they 

fired or, ‘‘re-educated more than a thousand clerics.’’

On the other hand, the fact of the matter is if one looks at the 

FBIS reports, the Foreign Broadcast Information Service reports, 

plus the Saudi media and Saudi television, which is openly available on satellite television, one can see routine demagoguery leveled against the United States, against Christians and Jews routinely. Saudi websites features are the demonization of Jews and 

Christians as well as moderate Muslims. And I think you should 

be aware of something else, very disturbing. This incitement is not 

36

necessarily illegal. It is considered free speech, and particularly in 

the United States. The problem is: How does one combat incitement within the context of an open society? 

It is my feeling that incitement needs to have the sunshine to expose the whole virus of extremism, and those groups, entities, individuals that are propagating the incitement need to be delegitimized, or invited to the United States, or embraced. And I 

think that goes to the heart of getting Saudi Arabia to understand 

and recognize that it must rein in the extremists that in turn breed 

the terrorists that carried out September 11. 

Chairman COLLINS. Thank you. May I do just one quick question 

for Mr. Winer? 

Senator SPECTER. Absolutely. 

Chairman COLLINS. Thank you. 

Mr. Winer, you have experience in a previous administration, 

and I am trying to better understand why the U.S. Government 

has not been tougher with the Saudis. Do you believe that one factor, aside, perhaps, from our bases or oil, but I have heard that the 

U.S. Government has been hesitant to go after some suspected 

financers of terrorist groups because they are prominent Saudi 

business people. Do you think that is accurate? 

Mr. WINER. Yes. 

Chairman COLLINS. Could you expand further on why you think 

the Federal Government under both the previous administration 

and perhaps this administration as well has been somewhat reluctant to fully confront the Saudi Government in the wake of all of 

this compelling evidence? 

Mr. WINER. I think a number of the factors are institutional and 

bureaucratic before you get to the additional factors pertaining to 

Saudi Arabia itself. 

First, institutionally and bureaucratically, the only businessmen 

really that the U.S. Government went after prior to September 11 

were Colombian businessmen who were also major cocaine traffickers. Prior to that, we used the International Emergency Economic Powers Act against countries or against military leaders, 

that kind of thing. These were businessmen. We were able to go 

after them because we found a computer in Colombia from the Cali 

cartel that listed all the businesses owned by these people who we 

had chapter and verse as drug traffickers. Easy case to make. Justice led making that case. Treasury, Mr. Newcomb strongly supported doing that because he felt all the facts were there, and it 

wasn’t going to put IEEPA powers at risk, because what the U.S. 

Government is worried about, if we reach too far and somebody 

who is well funded goes after us and says you don’t have the authority to do that, you don’t have the public evidence to do that, 

we might lose some of that power. So there is an institutional concern. Don’t overreach and then lose some of the power you have. 

Those are institutional and bureaucratic but very important constraints. 

In the area of Saudi businessmen, you have got the problem of 

the fragmentary nature of the information, the fact that money is 

fungible, and just because a businessman funded a huge charity 

and that charity engaged in terrorist logistical support and recruitment in the Philippines and in the Middle East and in Chechnya 

37

and Bosnia and wherever, while also doing lots of wonderful other 

things, how do you know that that businessman when he gave that 

money intended the bad things as well as the good things? A difficult case to make. 

So prior to September 11, you are having tremendous tensions 

over what is the right thing to do in light of those institutional 

issues, legal issues, practical issues, even before you get to the sensitivity of the Saudi relationship itself. The facts about terrorist finance, while voluminous, are also often rather murky and difficult 

to fully decipher. Our intelligence was poorly arrayed prior to September 11 to gather all the information we needed. The interagency 

process didn’t work as well as it should have, although Dick Clark 

tried valiantly to put it together and did, I think, a remarkable job. 

We didn’t have as many facts as we should have. But we went to 

the Saudis as a government, shared with them what we had, asked 

them for more information, warned them of what might take place, 

and ultimately nothing happened. I think those are all facts that 

are undisputable. The why’s and the wherefore’s and the what 

should’s are really up to you all to determine next. 

Thank you very much, Madam Chairman. 

Chairman COLLINS. Thank you, Senator Specter. 

Senator SPECTER. Thank you, Chairman Collins. Senator Pryor. 

Senator PRYOR. Thank you. 

Mr. Winer, if you can educate this Committee just very briefly, 

as I understand Saudi Arabia—tell me if this is true or not. But 

as I understand Saudi Arabia, the economic power and the political 

power really are merged into one in the sense of there are families 

and it is pretty much one and the same. 

Mr. WINER. I know of no facts to dispute that assessment. I think 

that is right. 

Senator PRYOR. OK. So sometimes when we talk about individuals doing something versus the government doing something, a lot 

of times it is a matter of an individual maybe in their personal capacity versus in some other official capacity, right? It is all a 

hodgepodge. It is all mixed up. Is that fair to say? 

Mr. WINER. Yes, sir. 

Senator PRYOR. One thing that we are sensitive to obviously here 

in this country is al-Qaeda as a terrorist organization. I know that 

Ambassador Gold has mentioned a few times, Hamas. In this country, we are not quite as tuned into that. But, Ambassador Gold, 

what other terrorist organizations in your personal view have ties 

to Saudi Arabia besides al-Qaeda and Hamas? 

Mr. GOLD. Well, many of these organizations are part of all the 

same network. In fact, al-Qaeda should probably be seen as a consortium of terrorist organizations where they use the assets, sometimes manpower assets, sometimes financial, conduit assets, sometimes expertise in explosives, and share them around the world. 

Some of those assets are in the Philippines. Some of those assets 

are in Indonesia. Some of those assets are in Chechnya and Dagestan in Russia. Some of those assets are in Egypt. And Hamas, by 

the way, is part of that network to a large extent. 

I think you can find the fingers of Saudi financial involvement 

through these charities with most of the countries that I mentioned. 

38

Let me just add one other point to my presentation at this time. 

Many times you are going to see Saudi denials, very firm denials, 

that they have cleaned up their act, that these charitable contacts 

around the world no longer are with suspected groups. For example, there was a press release put out on October 18, 2002, by the 

Saudi Embassy in Washington, and in it the Saudis asserted that, 

since September 11, all charitable groups have been audited to ensure that there are no links to suspected groups. 

Now, I don’t know what a suspected group is and they don’t clarify it, but you would think that a suspected group would be groups 

that are on the State Department list of terrorist organizations. 

Well, the very same month that in Washington the Saudis were 

putting this out as a press release to the Washington Press Corps, 

you had another little event going on in Riyadh, Saudi Arabia. You 

had a WAMY conference. And that photograph of Khaled Mashal, 

one of the highest leaders in the Hamas organization, was taken 

by Reuters at a WAMY conference in October 2002, the very same 

month. So, in Washington, they are saying that they are cutting off 

their contacts, the contacts of the charities, with suspected groups, 

yet in Riyadh you have the Saudis inviting one of the leaders of 

Hamas to a WAMY conference in Saudi Arabia. 

By the way, the Hamas actually prepared a record of Khaled 

Mashal’s meetings in Riyadh, and it was found by Israeli forces the 

following month in the Gaza Strip. And according to that record, 

Khaled Mashal was not just a peripheral guest of a peripheral organization, WAMY. He actually had a for-eyes meeting with Crown 

Prince Abdullah, who actually chaired that WAMY conference. 

Senator PRYOR. Mr. Winer, if I may ask you, with the increased 

financial security on terrorist organizations around the world, do 

you see some new tactics out there that they are trying to do to 

get around some of our efforts? And what are those tactics, and 

what do we need to be looking for? 

Mr. WINER. Yes, sir. One quick observation. I am not aware of 

any individual or entity that has been arrested for terrorist finance 

in Saudi Arabia to date. If there have been any such arrests, none 

of them have been publicly announced. 

As to new techniques, gold markets and precious metals generally, commodities, diamonds, as Senator Akaka raised before, remain essentially unregulated globally. Regulation of charities globally still is extremely poor, and charities remain a tremendous opportunity well outside Saudi Arabia for moving terrorist funds. 

The underground alternative remittance systems are still, by and 

large, extremely poorly regulated. In every country, we are beginning a crackdown. Here we have required them to register in theory. I am not sure whether that is as effective as it should be. Certainly registration of hawalas in the Middle East remains relatively 

minimalist in practice, and those networks are very substantial. 

Money continues to move back and forth in terms of currency from 

Yemen to Saudi Arabia and into and out of UAE. So our ability to 

track all of that, particularly in connection with remittances, some 

of which involve legitimate remittances and some of which don’t, is 

poor. And the religious schools around the world generally have no 

oversight in terms of movements of money. 

39

In the United States, if you go to the IRS filings for religious 

groups, mosques, synagogues, or churches—it doesn’t matter what 

religion—all you have to do is say, ‘‘I am a mosque,’’ ‘‘I am a 

church.’’ That is all you have to report to the IRS. There is no further detail in the public filings beyond that. That is in the United 

States, which is presumably one of the better regulated countries. 

So I think that is still a potentially significant problem. 

That said, formal financial institutions cannot risk being associated with terrorist finance. If the U.S. Government were to go after 

any major financial institution anywhere in the world with a terrorist finance designation, it would create such a chilling impact 

that one would imagine further due diligence, regulatory efforts be 

put into place by financial institutions all over the world to ensure 

that didn’t happen to them and to protect shareholder interests 

and equities. 

Thank you. 

Senator PRYOR. Thank you for that answer, and I want to thank 

the panel for being here. 

Senator SPECTER. Thank you, Senator Pryor. 

The Committee intends to pursue the question as to whether economic sanctions are being imposed, and there are very substantial 

indicators that they are not. When Saudi Arabia is involved, we are 

soft on economic sanctions. But there is a broader picture which is 

emerging, and that is the potential for criminal sanctions. 

We have held in the Judiciary Committee hearings several years 

ago on the focus on U.S. citizens being murdered in Israel by terrorist organizations. And we are pursuing the question of bringing 

those terrorists to the United States for trial. 

In 1986, we passed the Terrorist Prosecution Act, which gives 

extraterritorial jurisdiction to the United States to bring terrorists 

into our courts and to impose the death penalty. And there are two 

cases which we are currently focusing on with Israeli Attorney 

General Rubenstein and U.S. Attorney General John Ashcroft. One 

involves an individual who is in the United States where requests 

have been made to get witnesses to testify about his conduct involved in terrorism and murder of American citizens, and that evidence has to be provided by Israel. And contacts have been made 

at the very highest level with the Israeli Government, and some assurances have been received that there will be cooperation. 

There is another individual who confessed on television, with no 

question about the voluntariness of the confession. And the issue 

is getting that individual extradited to the United States, which is 

complicated because, as is well known, Israel does not have the 

death penalty. But there are exceptions under Israeli law where 

national security is involved. And when we go through the very impressive chart, Ambassador Gold, that you put up about Saudi national charities and the financing of international terrorism, and 

they are not non-governmental organization, they are governmental organizations, those individuals who finance Hamas are potentially liable for prosecution in the United States criminal courts 

because Hamas takes credit for the killings. The murders at Hebrew University were American. U.S. citizens were murdered. 

So this is a matter that we need to pursue further on the hard 

evidentiary line. But I think that economic sanctions are fine. I 

40

would like to see them imposed, but there is a lot more that can 

be done. 

Let me yield at this point to Senator Collins, and I will come 

back to questioning. 

Chairman COLLINS. I just want to thank you, Senator, for spearheading this investigation. It is important, and the evidence we 

have heard in the statements this morning from the experts are 

compelling in painting a picture of the Saudi Government’s many 

links to these charitable organizations and those organizations 

linked to terrorist groups. So I applaud your initiating this investigation, and I look forward to continuing to work with you. 

Senator SPECTER. Well, thank you. Thank you, Senator Collins. 

Senator Pryor, do you have any further questions? 

Senator PRYOR. No. 

Senator SPECTER. Then let me proceed just a bit further. 

Ambassador Gold, you have testified about the document which 

was signed by the current Palestinian Prime Minister requesting 

that Saudi official stop financing Hamas. Would you go through 

that again and elaborate on precisely what it says? 

Mr. GOLD. Well, we actually have an English translation. 

Senator SPECTER. That is from Abu Mazen? 

Mr. GOLD. Abu Mazen, yes. Also known as Mahmud Abbas. 

Senator SPECTER. Who is the Palestinian Prime Minister. 

Mr. GOLD. He is the Palestinian Prime Minister, and he wrote 

in his own handwriting a fax that was sent to Prince Salman, the 

governor of Riyadh and full brother of King Fahd, probably the 

fourth most powerful man in Saudi Arabia. And I can just read this 

paragraph to you that I have on the screen, which is an exact 

translation of the relevant material. 

Senator SPECTER. Please do. 

Mr. GOLD. ‘‘I hereby wish to inform you that he’’—meaning Yasser Arafat—‘‘has spoken with me on the telephone and asked me 

to transmit to you his request that you mediate and interfere and 

express his view concerning the ongoing situation in our homeland. 

The Saudi committee responsible for transferring the donations to 

beneficiaries has been sending large amounts to radical committees 

and associations, among which the Islamic Society’’—that is a 

translation of al-Jamiya al-Islamiyah—‘‘which belongs to Hamas, 

the al-Islah Association’’—an association known to be a Hamas institution in Gaza—‘‘and to the brethren who engage in jihad in all 

regions. This fact badly influences the internal situation. It also results in strengthening these brethren and has, therefore, a negative impact on all sides. Moreover, the Committee does not send 

any money or assistance to members of Fatah.’’

So this is, again, written not by an Israeli but by perhaps the No. 

2 man in the Palestinian Authority today——

Senator SPECTER. Perhaps the No. 1 man. 

Mr. GOLD. Well, a lot of people are hoping to make him the No. 

1, Prime Minister Mahmud Abbas. It is in his own handwriting, 

and it was written in December 2002. 

Senator SPECTER. I will come to you in a minute, Mr. Winer. 

And it is directed to whom, again? 

41

Mr. GOLD. Prince Salman is the governor of Riyadh, and it is directed to him. He is a full Sudairi brother of King Fahd, and I 

would say about the fourth most powerful man in Saudi Arabia. 

Senator SPECTER. Do you have a judgment as to why the letter 

was written to him? 

Mr. GOLD. Well, apparently they had sent messages to others as 

well, such as Prince Naif. But Salman has always been a kind of 

critical figure in many of the charitable enterprises, and perhaps 

that was why he was chosen. 

Senator SPECTER. And when the last line says that no contributions were given to Fatah, what do you make of that? 

Mr. GOLD. Well, I think here there is a desire, clearly, to make 

sure that all resources coming from Saudi Arabia go through the 

Fatah organization, which is the largest national component inside 

the Palestinian Authority. They want the money in their hands 

and not going to Hamas. 

I think the importance of this document is that it clearly indicates that Saudi Arabia was funding Hamas in the year 2000, and 

we would say, as I said earlier, that funding is continuing to this 

day, in fact, becoming more significant as we speak. 

Senator SPECTER. Mr. Winer, you had your hand up indicating 

a wish to say something? 

Mr. WINER. It relates to this topic. Last year, FBIS reported that 

President Musharraf in Pakistan sent a similar communication to 

senior Saudi officials asking the Saudi Government to stop funding 

or Saudi Arabia to stop funding radical militants in madrassas in 

Pakistan who were creating problems of Islamic militancy within 

Pakistan for President Musharraf. 

Senator SPECTER. What do you think we ought to do about that, 

Mr. Winer? You are a former State Department official. 

Mr. WINER. I think that the Congress and the White House still 

speak with the bully pulpit, that they are communicating, as you 

are doing today, is important. Beyond that, I think sanctions have 

to be taken against particular entities, when we have sufficient evidence to determine that an entity, regardless of who——

Senator SPECTER. How about sanctions against the Saudi Arabian Government? 

Mr. WINER. I think the first thing to do is sanctions against economic entities that are substantial where we have definitive information that those entities have been used to fund terrorism. That 

is what our law permits. That is what we have warned Saudi Arabia, among others, we could do. To the extent that we have the 

ability to do that and the evidentiary packages are sufficient, I 

think we should do it. That is my opinion. 

Senator SPECTER. Ambassador Gold, to what extent, as you 

produce documents and show charts, is there an evidentiary chain 

which would go to these officials of the Saudi Government who are 

chairmen of these organizations, IIRO, WAMY, al-Haramain, to 

show the connection between those individuals and their direction 

of funds through these specific organizations to Hamas, which then 

results in the murders of U.S. citizens? 

Mr. GOLD. I cannot supply the evidence to show that the heads, 

the chairmen of these organizations know where every dollar is 

going in these particular allocations to Hamas. But, again, the maVerDate 0ct 09 2002 08:39 Jan 30, 2004 Jkt 089039 PO 00000 Frm 00045 Fmt 6633 Sfmt 6601 C:\DOCS\89039.TXT SAFFAIRS PsN: PHOGAN
42

terial showing that the organizations are allocating to Hamas is 

clear-cut. 

I would say there is one other aspect here, I think, that should 

be taken into account. I cannot speak about how the U.S. Government should respond. I am an Israeli citizen. But we are now——

Senator SPECTER. We are going to reserve those questions for 

State Department officials. We are not going to ask an Israeli 

former Ambassador to tell us what to do. 

Mr. GOLD. But I will comment on one aspect affecting policy 

today because the United States is now leading the way to implement what is called the road map, a performance-based road map 

to a permanent two-state solution. And in phase one of the road 

map—this is from the Department of State website—you can see 

that Arab States are expected to cut off public and private funding 

and all other forms of support for groups supporting and engaging 

in violence and terror. Therefore, I would say the crown jewels of 

U.S. Middle East policy, that is, the road map, specifically refers 

to cases like Saudi Arabia. In short, Saudi Arabia ought to go 

under the road map. 

I would also add that at the Sharm El-Sheikh Summit on June 

3, 2003, President Bush made a declaration in which he said he 

had the assurances of all those present that there would be no 

more terrorist funding, and here is the actual phrase that he used 

at the summit: ‘‘The leaders here today have declared their firm rejection of terror regardless of its justifications. They have also committed to practical actions to use all means to cut off assistance, 

including arms and financing, to any terror group.’’

So what you have is clear-cut U.S. policy to make sure that 

Saudi Arabia doesn’t continue funding Hamas. I would say from 

the testimony you have heard today, the same networks that are 

working with Hamas are also working with al-Qaeda. If you make 

sure that the funding to Hamas stops, you will also, to a large extent, improve the national security of the United States by cutting 

off the funding routes to al-Qaeda as well. 

Senator SPECTER. Ambassador Gold, when you say you can not 

say that these officials in these organizations, these governmental 

officials knew where every dollar went, I can understand that. But 

if they know that there are some dollars going to Hamas and they 

know Hamas is engaged in terrorism, and that terrorism results in 

murders of U.S. citizens, that is—you don’t have to find where 

every dollar goes. You just have to be able to prove that they know 

that some dollars are going to terrorists. 

Mr. GOLD. I would suggest they have a kind of corporate responsibility standing at the head, at the apex of these organizations to 

know about it. 

Senator SPECTER. You can not establish criminal liability as the 

head of a corporation. You have got to prove that they knew what 

was going on, knowledge, participation, and acquiescence. 

Mr. GOLD. The documents that I can supply can show the organizations’ links to Hamas. I can also show you how the organization 

is structured. But you would have to go probably to U.S. agencies 

to find out whether any other information is available linking these 

individuals to Hamas funding. 

43

Senator SPECTER. And when you have the connection to alQaeda, it is a much broader criminal responsibility. There you have 

the murders of 3,000 American citizens. 

Mr. GOLD. That is absolutely true. But, again, I will only make 

statements here about things that I can document. What I have 

stated in this Committee hearing I can document. 

Senator SPECTER. Well, the statement by the President that you 

have got on the board is about as good as you can get for him to 

extract those promises from the leaders of Saudi Arabia and other 

countries. And now the issue is pursuit to see to it that they live 

up to what they have said. 

One other subject before adjourning. Mr. Emerson, your comment, I think, about the 7th graders who were having hate materials in their educational portfolios, that has been a problem ongoing for quite a long time. We have seen in the Palestinian Authority materials in grade schools, and part of the funding of the Palestinian Authority after Oslo, before we stopped the funding, was 

conditioned on changing, taking those materials out of the textbooks. 

You have had considerable experience in this field. What recommendations would you have as to how to deal with the problem 

of this hate literature going to the next generation? 

Mr. EMERSON. I think it is probably the most frustrating problem 

to deal with insofar as asking Saudi Arabia to stop the incitement 

within its own borders is basically asking it to essentially renounce 

its own Wahhabist ideology. There is a fundamental contradiction 

here. 

On the other hand, as a result of the Riyadh attacks, I think 

more members of the family realize that the tiger is now coming 

to bite it and it cannot afford to keep paying off cooptation money 

overseas or even trying to essentially incite its citizens against 

Christians or Jews or Israelis or Americans in an effort to dissuade 

them from being frustrated with the regime itself. 

But there is a fundamental contradiction here. My belief is that 

Saudi Arabia, as you have noted here, should be subject to the 

sanctions that were empowered by the PATRIOT Act because of 

the fact that foreign national central monetary institutions are allowed to be subject to sanctions if their funding mechanisms do not 

stop or are aware of terrorist financing. And I think the body of 

evidence of terrorist ties going back for the last 15 years on 

WAMY, IIRO, al-Haramain, and several other Saudi, ‘‘NGOs are so 

demonstrably present that it would be reckless disregard for anyone to say that they were unaware of those ties, let alone not taking responsibility.’’

At this point, I can tell you based on the information we have 

collected that there are direct ties between Saudi Government officials, the members of the family—not all, but some—and all of 

those NGOs in terms of the financial support and the largesse they 

receive. 

One other point I would just like to add, because you have been 

very good in terms of pressing the government to make sure that 

it does not succumb to any political pressure. I can tell you based 

on discussions that I have had with law enforcement officials and 

prosecutors that while no one has said to me that they received a 

44

red light from the State Department, they have repeatedly expressed their frustration at the resistance within the government 

decisionmaking process to fully give them the green light to go 

after and conduct criminal investigations against Saudi entities 

and individuals. Part of the frustration is because Saudi Arabia 

has provided diplomatic immunity or actually pulled back some of 

the key witnesses, material witnesses that were being held here or 

subject to investigation and not made them available to the U.S. 

Government. 

In other cases, it is the fear of antagonizing the Saudi regime 

that has basically put a red light to some of the key law enforcement prosecutions that are being considered at this point as we 

speak. 

Senator SPECTER. Well, first you say there is no red light, and 

then you say there is not a green light. And we are not looking for 

amber in between. And then you just concluded by saying that 

there was a red light on criminal investigations. Could you amplify 

that a bit? 

Mr. EMERSON. The red light insofar as a document that says we 

will not support a criminal investigation because of fear of engendering antagonism of the Saudi regime, I know of no such document that would ever be produced. 

Senator SPECTER. Well, you wouldn’t necessarily expect to have 

a document under seal, notarized. You might have a conversation. 

Who would want to put that in writing? Some congressional committee might get a hold of it. 

Mr. EMERSON. Right, but you might not even have the conversation. It might just die, on the wane. In other words, it might not 

be acted upon. 

Senator SPECTER. Well, there would be a reason for why it wasn’t 

acted upon. 

Mr. EMERSON. Well, there would be some type of bureaucratic 

reasons. Look, I can tell you documents we received under FOIA 

going back to 1996, 1997, and 1998, show that certain radical Islamic charities were being categorized as terrorist conduits back in 

those years—and yet they weren’t frozen or had any sanctions 

against them until 2001. So something intervened to stop that designation and stop the asset forfeiture. 

Now, I can not tell you what stopped it because I haven’t received the documents—and I deal only with empirical evidence. But 

I know something stopped it, and I can only imagine that it was 

diplomatic pressure. 

Senator SPECTER. Well, those are subjects we are going to pursue. One final comment. When you talk about Saudi textbooks responding to Wahhabi philosophy, there is a limit to how far you 

can go, even under those circumstances, as far as inciting murder. 

That crosses international lines, and it is an international crime. 

And we have got to look at the toughest lines, economic sanctions, 

criminal sanctions, whatever it takes. 

Well, thank you very much, gentlemen. I think this has been informative, and stay tuned. 

[Whereupon, at 12:41 p.m., the Committee was adjourned.] 

(45)

A P P E N D I X 


89039.001
46


89039.002
47


89039.003
48


89039.004
49


89039.005
50


89039.006
51


89039.007
52


89039.008
53


89039.009
54


89039.010
55


89039.011
56


89039.012
57


89039.013
58


89039.014
59


89039.015
60


89039.016
61


89039.017
62


89039.018
63


89039.019
64


89039.020
65


89039.021
66


89039.022
67


89039.023
68


89039.024
69


89039.025
70


89039.026
71


89039.027
72


89039.028
73


89039.125
74


89039.126
75


89039.127
76


89039.128
77


89039.029
78


89039.030
79


89039.031
80


89039.032
81


89039.033
82


89039.034
83


89039.035
84


89039.036
85


89039.037
86


89039.038
87


89039.039
88


89039.040
89


89039.041
90


89039.042
91


89039.043
92


89039.044
93


89039.134
94


89039.135
95


89039.136
96


89039.137
97


89039.138
98


89039.139
99


89039.140
100


89039.141
101


89039.142
102


89039.143
103


89039.144
104


89039.145
105


89039.146
106


89039.147
107


89039.148
108


89039.149
109


89039.150
110


89039.045
111


89039.046
112


89039.047
113


89039.048
114


89039.049
115


89039.050
116


89039.051
117


89039.052
118


89039.053
119


89039.054
120


89039.055
121


89039.056
122


89039.057
123


89039.058
124


89039.059
125


89039.060
126


89039.061
127


89039.062
128


89039.063
129


89039.064
130


89039.065
131


89039.066
132


89039.067
133


89039.068
134


89039.069
135


89039.070
136


89039.071
137


89039.072
138


89039.073
139


89039.074
140


89039.075
141


89039.076
142


89039.077
143


89039.078
144


89039.079
145


89039.080
146


89039.081
147


89039.082
148


89039.083
149


89039.084
150


89039.085
151


89039.086
152


89039.087
153


89039.088
154


89039.089
155


89039.090
156


89039.091
157


89039.092
158


89039.093
159


89039.094
160


89039.095
161


89039.096
162


89039.097
163


89039.098
164


89039.099
165


89039.100
166


89039.101
167


89039.102
168


89039.103
169


89039.104
170


89039.105
171


89039.106
172


89039.107
173


89039.108
174


89039.109
175


89039.110
176


89039.111
177


89039.112
178


89039.113
179


89039.114
180


89039.115
181


89039.116
182


89039.117
183


89039.118
184


89039.119
185


89039.129
186


89039.130
187


89039.131
188


89039.132
189


89039.133
190


89039.120
191


89039.121
192


89039.122
193


89039.123
194

Æ


89039.124